Abouammo v. United States

Questions presented

SCOTUS records, cert granted 5 Dec 2025

1. As part of an investigation into a scheme to disclose nonpublic Twitter account information to foreign actors, San Francisco-based FBI agents visited Petitioner Ahmad Abouammo at his home in Seattle. While they were there, Mr. Abouammo went upstairs and emailed them an allegedly falsified document. Mr. Abouammo's only interaction with the agents occurred in Seattle. A grand jury in the Northern District of California indicted Mr. Abouammo for (among other things) falsifying documents with the intent to impede an investigation. The parties then agreed to toll the statute of limitations for other uncharged offenses. On the day the tolling agreement expired, the government filed a superseding information adding various felony counts. Mr. Abouammo never waived prosecution by indictment. See Fed. R. Crim. P. 7(b). Four months after the limitations period had expired, the government dismissed this placeholder information and replaced it with a superseding indictment containing the same charges. The questions presented are:
2. Whether venue is proper in a district where no offense conduct took place, so long as the statute's intent element "contemplates" effects that could occur there.
3. Whether a criminal information unaccompanied by a waiver of indictment is an "information charging a felony" that allows the government to unilaterally extend the statute of limitations under 18 U.S.C. § 3288.

Opinion summary

Etalia.ai summary of the majority opinion

Justice Kagan wrote for a unanimous Court. The case asked where a defendant may be tried for violating 18 U.S.C. § 1519, which criminalizes knowingly falsifying a document with intent to obstruct a federal investigation. The Court held that venue lies only in the district where the falsification occurred, not in the district where the investigation was located. The Court reasoned that the only conduct the statute prohibits is falsifying the document, and the intent to obstruct does not change the place of that conduct. It also rejected the government's view that § 1519 is an inchoate offense tied to some other obstruction crime, explaining that it is a standalone offense. Because the falsification here happened in Seattle, trial in the Northern District of California was improper.