United States v. Seward, No. 18-1519 (1st Cir. 2020)
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The First Circuit denied Defendant's motion to dismiss the indictment for failing to update his registration as required by the Sex Offender Registration and Notification Act (SORNA), 18 U.S.C. 2250(a), holding that venue for a section 2250 prosecution is proper in the departure jurisdiction.
Defendant, a state sex offender, failed to update his registration after he moved from Massachusetts to New York. Defendant was indicted in Massachusetts for his failure to register. Defendant filed a motion to dismiss, arguing that, under the Supreme Court's decision in Nichols v. United States, 136 S. Ct. 1113 (2016), he committed no crime in Massachusetts because his failure to register occurred in New York. The district court denied the motion, concluding that venue was proper where Defendant's interstate travel began. The First Circuit affirmed, holding that venue for Defendant's prosecution was proper in Massachusetts because the nature of the offense shows that its locus delicti encompasses the departure jurisdiction.
The court issued a subsequent related opinion or order on August 18, 2020.
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