Overview
- The Supreme Court unanimously held that prosecutions under 18 U.S.C. §1519 must be tried in the district where the false document was created, not where investigators were based.
- The ruling, issued June 11, 2026, overturned Abouammo’s obstruction/falsification conviction because the fake invoice was created in Seattle while his trial took place in San Francisco.
- The Court left Abouammo’s other convictions—unregistered foreign-agent, wire fraud, and honest-services fraud—intact for now.
- The case has been remanded to lower courts and is likely to be transferred to the Western District of Washington for a retrial or disposition of the vacated falsification count.
- Legal analysts and the Cato Institute say the narrow statutory holding could still narrow Justice Department venue choices and prompt challenges in other cases where prosecutors tried counts away from the locus of the conduct.