18 U.S.C. § 1519 prohibits only one act: that of falsifying a document. Today, in an unanimous opinion written by Justice Kagan, the Supreme Court held that “[t]he trial for falsifying a document must take place where the defendant falsified the document.” Abouammo v. United States, No. 25-2546 (June 11, 2026).
While employed by Twitter at its San Francisco office, petitioner Ahmad Abouammo provided confidential information to a Saudi official about Saudi dissidents posting on the company’s platform. In exchange, the official wired Abouammo $300,000. Around the same time, Abouammo left Twitter and relocated to Seattle, where he started a social-media consulting business.
Two San Francisco based FBI agents, who were investigating unauthorized disclosures of Twitter account information, later flew to Seattle to interview Abouammo at his home. During the interview, Abouammo denied giving the Saudi official confidential information, claiming that the payments were for consulting work. When the agents asked for supporting documentation, Abouammo went upstairs, created a fake invoice, and emailed it to one of the agents. Back in San Francisco, the agents discovered from the emailed document’s date-and-time metadata what Abouammo had just done.
Abouammo was indicted in the Northern District of California for falsifying a record under §1519. He moved to dismiss the charge for improper venue, arguing that he could be tried only where the alleged falsification occurred. The District Court denied the motion, finding venue also proper in the place where the FBI investigation was located, and a jury convicted Abouammo. The Ninth Circuit affirmed, reasoning that §1519’s intent requirement—“with the intent” to “obstruct” an investigation—made the “contemplated effects” of the falsification part of the “essential conduct” of the offense, thereby permitting trial “where the investigation” the defendant “intended to stymie [was] ongoing or contemplated.”
The Supreme Court reversed. A defendant charged with violating §1519 must be tried in the district where the falsification occurred:
[T]he crime is complete upon falsification …. And that fact makes the venue inquiry straightforward. Because the only proscribed conduct is falsification, venue must be where falsification occurred. Here, that means venue must be in the district encompassing Seattle, where Abouammo created the false invoice. It could not be in the Northern District of California, hundreds of miles away from that prohibited conduct.
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