October Term 2025 · Docket 25-5146

Where Does a Fraud Crime Happen When a False Record Is Made on a Computer?

Abouammo v. United States asks the Supreme Court to decide where a federal fraud crime counts as happening. The dispute is whether a trial can take place in San Francisco when the person created a false record elsewhere. The answer decides where the trial can occur.

Official caption
Abouammo v. United States
Latest argument session
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Decided
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Verified source milestones

  1. — An official oral-argument transcript was verified.
  2. — An official oral-argument transcript was verified.
  3. — An official Court opinion was verified.
  4. — An official Court opinion was verified.

The arguments, in order

This case may have been argued more than once. Each entry below uses that session's official transcript. Later arguments do not erase earlier ones.

  1. Argument 1 ·

    What happened at the argument

    This session was the only argument held. No reargument occurred, so nothing here covers a later session.

    The side that brought the case asked the Court to hold the Section 1519 offense was committed in San Francisco. His reasoning: the crime completes upon falsification, with intent coinciding at that moment. No communication, effect, or investigation is required. He cited Travis, Armour Packing, and Johnson.

    He argued Lamar required a communicative assertion, comparing it to Palliser. He said venue is count-specific and waivable, using a Cabrales analogy. He noted the government's own trial position placed falsification on the defendant's computer. He agreed Section 1512(c) differs because it requires effects.

    The government asked the Court to uphold trial where the investigation was actually affected. Its reasoning: the transmission targeted that district, like shooting and hitting it. It cited Ford and Lamar for detrimental effects supporting venue. It conceded the elements were complete before transmission and effects are not elements. It argued Cabrales is backward-looking while Section 1519 is forward-looking.

    Read the official transcript for this argument · Official argument details

    Sources used for this argument breakdown

A citizen's guide to the whole case

What this case is about

This case involves a federal law called Section 1519. It punishes someone who creates a false record to hide something. The parties disagree about when that crime is complete and where it happens.

Official sources for this section

How the case got here

The case reached the Supreme Court as No. 25-5146. The Court held oral argument on March 30, 2026, in Washington, D. C. The record does not describe the lower court's decisions.

Official sources for this section

What each side wants

Tobias S. Loss-Eaton argues for the side that brought the case. He asks the Court to hold the crime happened in San Francisco. He says the crime was complete when the false record was created, with no sending or effect required.

Anthony A. Yang argues for the government. It asks the Court to allow trial where the investigation was actually affected. It says the sending targeted another district, like a shot aimed at a target.

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What each side says

The side that brought the case says Section 1519 is complete upon falsification. He says intent must coincide with that falsification. He says duplicates are not separate falsifications and no metadata evidence was shown. He cites older cases supporting a location tied to the physical act.

The government concedes the crime's elements were complete before any transmission. It concedes effects are not elements. It concedes that without transmission, venue would follow where the act occurred. But it argues the sending actually affected the investigation district. It cites cases about detrimental effects supporting venue.

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What the justices asked

Justice Thomas asked whether saving a draft completes the crime. Justice Sotomayor asked how intent can be proven without sending. Justice Kavanaugh asked whether intent to impede must be shown. He also tested the government's theory against a shredding-at-home example.

Justice Alito asked where the crime happens if the material is emailed to San Francisco. Justice Kagan asked how the government's theory differs from the lower court's approach. Justice Sotomayor questioned who decides the extra-textual intent requirement the government proposes.

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Why it matters

Venue rules decide where a person faces trial. That choice affects convenience, local juries, and prosecution strategy. The ruling could shape how courts locate crimes committed on computers. It may also clarify whether effects on investigations can anchor a trial.

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What the Court decided

A person charged with falsifying a document to obstruct a federal investigation must be tried where the falsification happened, not where the investigation was located. A statute's intent requirement does not change that, because the only forbidden act is the falsification itself.

The Ninth Circuit's judgment was reversed and the case was remanded for further proceedings.

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Official Court provenance

Official docket and case history · Official Supreme Court oral-argument detail page

Verified official opinions and orders

Title and summary sources

Revision history

  1. Revision 1 · Official Transcript ·
  2. Revision 2 · Official Transcript ·

    Correction: Rewritten to the concise citizen-facing editorial standard.

  3. Revision 3 · Official Transcript ·

    Correction: Removed an unsupported statement that the Court had not ruled; the available source set did not establish that absence.

  4. Revision 4 · Official Transcript ·

    Correction: Corrected unsupported no-ruling language and clarified that the article's disposition summary is incomplete.

  5. Revision 5 · Post Opinion ·

    Correction: Added the holding and disposition from the verified official Court opinion.

  6. Revision 6 · Post Opinion ·

    Correction: Migrated to the dated official Court activity contract without model use.

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