Abouammo v. United States
In brief
A §1519 prosecution must be brought where the alleged falsification happened, not merely where its intended effects or an investigation were located.
- Where it stands
- Decided
Decided 9-0 · June 11, 2026 · Opinion by Justice Kagan
- What it’s about
- The Supreme Court unanimously ruled for Ahmad Abouammo, holding that a charge under 18 U.S.C. §1519 for falsifying a document to obstruct an investigation must be tried where the alleged falsification occurred.
- Who it affects
- Federal prosecutors must bring §1519 cases where the alleged false record or document was created or altered. For example, a defendant cannot be tried where an investigation occurred if no offense conduct happened there.
Summary: written with AI from the case record.
What it's about
Because no conduct constituting that offense occurred in the Northern District of California, the government could not prosecute him there merely because the targeted investigation was located there.
The decision reinforces the Constitution's requirement that criminal trials take place where the crime was committed.
Question presented
Is venue proper in a district where no offense conduct took place, so long as the statute’s intent element “contemplates” effects that could occur there?
What the Court decided
The vote
From the opinions
“A defendant charged with violating §1519 must be tried in the district where the falsification occurred.”
What's next
The case returns to the lower courts after the Ninth Circuit's decision was reversed and remanded. Lower courts and prosecutors must apply the Court's venue rule in future §1519 cases.
Docket activity
Case data updated: summary, question_presented, generation_metadata
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Opinion added: Opinion of the Court - EK
Audio Recording added: Oral Arguments - Abouammo
More questions
- What did the Supreme Court rule in Abouammo v. United States?
- The Court ruled that §1519 defendants must be tried where the alleged falsification occurred. An investigation's location alone cannot establish venue.
- Who is affected by the Abouammo decision?
- Federal prosecutors and people charged under §1519 are directly affected. Prosecutors must file cases in the district where the alleged false conduct happened.
- What happens next in Abouammo v. United States?
- The case returns to the lower courts for further proceedings. They must follow the Supreme Court's rule on where a §1519 trial may occur.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.