We will hear argument first this morning in case 25-51-46, Abu Amo versus United States.

Mr. Lossitin?

Mr. Chief Justice, and may it please the Court, the question here is whether Mr. Abu Amo committed

his Section 1519 offense in San Francisco.

In Section 1519, Congress created a broad document integrity offense, distinct from obstruction,

that requires no communication, no obstructive effects, and no investigation.

Under that broad law, Mr. Abu Amo's offense started and ended in a 30-minute window

during which he never left his home in Seattle.

He was guilty, and his offense was complete the moment he finished creating the false

invoice with the requisite intent. Whether he sent it to investigators, whether it affected

them in some way, or whether an investigation even existed at all, none of that is relevant to liability under the statute.

So the government didn't have to charge any of that in the indictment or prove any of it at trial.

But the government now wants to have it both ways.

It says the uncharged, unproven effect of Mr. Aboulam's offense means that he committed it in San Francisco.

That is wrong. From the common law through the founding era and up through this Court's

decisions in Cabrales and Rodriguez-Morano, venue has always turned on the location of the

offense's essential conduct. That is the question that this Court's venue cases all ask, even if not always in so many words.

Here, Section 1519 has one essential conduct element, falsification, and Mr. Abuamo did that entirely in Seattle.

Sending the document to investigators may have been evidence of his intent, but it was not essential for

conviction, so it cannot support venue. In arguing to the contrary, the government relies on

general, out-of-context language from cases addressing very different offenses, and it all but ignores

Johnson, Cabrales, and the ratification era understanding of where similar offenses were committed.

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