Where conspiracy trials happen
Pierre Yvelt Almonor v. United States
In brief
- Where it stands
- Petition Pending
Awaiting an order on the petition
- What it’s about
- Pierre Yvelt Almonor asks the Supreme Court to review his conviction for agreeing with others to commit crimes (conspiracy) in North Carolina, arguing that trial venue relied on acts by a co-conspirator he says he did not know existed.
- What's at stake
- Almonor's challenge to his conviction remains unresolved; the Supreme Court has not decided whether his arguments are right.
Summary: written with AI from the case record.
What it's about
He also argues that scams linked through a shared organizer and methods did not form one conspiracy.
Almonor argues that his trial was held in North Carolina based on acts by a co-conspirator he says he did not know existed. He also disputes treating schemes linked through a shared organizer and methods as one conspiracy.
The Constitution ties where a criminal trial may be held to where the crime was committed.
Question presented
1. Whether—as the Second Circuit holds but the Third, Fourth, Sixth, and Ninth Circuits deny—for a co-conspirator’s act to justify criminal venue, it must have been reasonably foreseeable to the defendant that the act would occur in the district where venue is sought. 2. Whether proving a single hub-and-spoke conspiracy requires proof of a connection between the spokes beyond shared methods of criminality and involvement with the hub—as this Court held in the seminal case of Kotteakos v. United States, 328 U.S. 750 (1946)—or whether, as the court below determined, a single conspiracy can be proved through “overlap of the key actors [i.e., the hub individuals] and the same methods, goals, nature, and results in each * * * scheme[].” App., infra, 6a.
What happens next
The Court must decide whether to hear the petition. No oral argument or decision date is scheduled.
Documents
Docket activity
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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.