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Criminal Resource Manual 1330 National Stolen Property Act -- Venue

1330

National Stolen Property Act—Venue

Venue for offenses under 18 U.S.C. § 2314 are governed by the provisions of 18 U.S.C. § 3237. In other words, the defendant may be prosecuted in any district where the interstate transportation was begun, continued, or completed. The essence of the offense under the second paragraph of 18 U.S.C. § 2314 is the interstate transportation of the victim and hence venue would exist in any district that the victim began, continued, or completed his interstate journey, see United States v. Coppola, 486 F.2d 882 (10th Cir. 1973). However, since the statute also prohibits acts of inducement, venue probably also exists where such acts were made or had their effect. (Compare with venue under the obstruction of justice statute, see the this Manual at 1738.
Venue for an offense under 18 U.S.C. § 2315 would normally be where one of the enumerated acts was performed. But see United States v. Melia, 741 F.2d 70 (4th Cir. 1984).

[cited in USAM 9-61.200]

Updated February 19, 2015