Docket 25-5146
Abouammo v. United States
DecidedJun 11, 2026
9-0unanimous decision
Source: CourtListener.
Court rules document-falsification trials must be held where the falsification occurred
What it does
The Court held that a trial for falsifying a document under §1519 must be held in the district where the defendant actually created or altered the false document — not in a different district where the investigation the defendant intended to obstruct was based. The statute's "intent to obstruct" language does not expand the permissible trial location to wherever the targeted investigation was located. Because the only act the law prohibits is the falsification itself, venue is fixed to the place where that act occurred.
Who benefits
People charged with document falsification under §1519 who committed the act in a district different from where the federal investigation was based — they can now only be tried in the district where they physically falsified the document, which may be closer to their home.
Who is affected
Federal prosecutors who investigate crimes spanning multiple districts — they lose the ability to bring §1519 document-falsification charges in the district where their investigation is headquartered if the falsification itself happened elsewhere.
Practical impact
Ahmad Abouammo's conviction in the Northern District of California is reversed and the case is sent back for further proceedings, because the falsification occurred in Seattle (Western District of Washington) — the only proper venue. Going forward, federal prosecutors charging someone under §1519 must bring the case in the district where the document was falsified, even if the investigation being obstructed was run out of a different city or state entirely.
Majority reasoning
The Court reasoned that the Constitution — in both Article III and the Sixth Amendment — guarantees that a criminal defendant be tried in the state and district where the crime was committed. To find where a crime was committed, courts look to the "essential conduct elements" of the offense: the specific acts a defendant must perform to violate the law. Under §1519, the only prohibited act is falsifying a document; once that act is done with the required intent, the crime is complete and nothing more needs to happen. The Court rejected the Ninth Circuit's reasoning that the statute's "intent to obstruct" language made the contemplated effects of the falsification — such as where the targeted investigation was located — part of the crime's conduct elements, explaining that intent requirements describe a defendant's state of mind, not additional acts, and a falsification happens wherever it physically occurs regardless of what the defendant was thinking. The Court also rejected the government's argument that §1519 is an "inchoate offense" (a crime that is a step toward committing another crime, like attempt or conspiracy), finding instead that §1519 is a standalone crime — a person can violate it by falsifying a document and locking it in a drawer, never using it to actually obstruct anything.
Constitutional question
When a defendant is charged with falsifying a document to obstruct a federal investigation under 18 U.S.C. §1519, must the trial be held in the district where the falsification took place, or can it also be held in the district where the federal investigation was located?
Precedent changed
The Court extended and applied the conduct-elements venue framework from United States v. Rodriguez-Moreno, 526 U.S. 275 (1999), and United States v. Johnson, 323 U.S. 273 (1944), to §1519, clarifying that intent-based elements do not expand permissible venue beyond where the prohibited act occurred.