Continuing-offense venue for § 841(a)(1) possession with intent to distribute / distribution (18 U.S.C. § 3237(a))

AND · 21usc841:x-venue

Under 18 U.S.C. § 3237(a), possession with intent to distribute and distribution across multiple districts are continuing offenses prosecutable in any district in which the offense was begun, continued, or completed.

Exact element source

to manufacture, distribute, or dispense, or possess with intent to manufacture, distribute, or dispense, a controlled substance; or

Source: docroot/ir/usc/title21.jsonl#title21_sec841; Unicode character offsets [151:282] (end exclusive); SHA-256 ebaba73bf6e21a591f44bf851f24a052a5687813c505030cd9483e17753e9420.

Routes and case patterns

Curated routes and observed case patterns
Route	Definition	Merits instance blocks	Distinct merits cases	Examples (up to 3 cases per count group)
_whole accepted; provisional (1 case)	The element is decided as a whole: the reasoning turns on no narrower doctrinal sub-question that distinguishes it from any other application of this element.	0 Satisfied 0; not satisfied 0; excluded context 1	0	Used only in non-merits blocks (1). Excluded context examples: United States v. Tiangco — 225 F. Supp. 3d 274 (2016) · United States District Court for the District of New Jersey · 2016 — satisfied · law (21usc841: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) · applied/procedural · not counted Pattern: continuing-offense/drugs-shipped-by-courier-into-forum-district

How courts decided this element

Annotation blocks, including explicitly excluded context
Case	Element	Holding and scope	Pattern	Exact source quotations
United States v. Tiangco — 225 F. Supp. 3d 274 (2016) · United States District Court for the District of New Jersey · 2016 — satisfied · law (21usc841: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)	Continuing-offense venue for § 841(a)(1) possession with intent to distribute / distribution (18 U.S.C. § 3237(a))	satisfied Excluded from merits counts applied / procedural basis: law; claim: (a)(1),(b)(1)(A); count: Count 2; theory: venue in the District of New Jersey as a district into which a continuing offence continued (18 U.S.C. 3237(a)); subject: count=Count 2; theory=venue in the District of New Jersey as a district into which a continuing offence continued (18 U.S.C. 3237(a)) Venue is proved by a preponderance and was also submitted to the jury; the judge treats it as a legal dispute on uncontested facts. Distinguishes Tingle (7th Cir.): a completed hand-to-hand distribution in district 1 does not give venue where a third party later redistributes.	continuing-offense/drugs-shipped-by-courier-into-forum-district	The government concedes that all of Ms. Tiangco’s physical actions with respect to Count 2 took place in Nevada. Source: `docroot/ir/caselaw/f_supp_3d_225.jsonl#/f-supp-3d/225/0274-01`; Unicode character offsets [22507:22619] (end exclusive); SHA-256 `7c9b8effe79b40465d8f54b688db37727be6b83430d03638ebb585ba402cc592`. Evidence kind: fact; polarity: cuts-against; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged) Ms. Tiangco sealed and deposited a package with UPS for delivery in New Jersey. This process was underway and ongoing, within the State of New Jersey, until the agents diverted the package. Source: `docroot/ir/caselaw/f_supp_3d_225.jsonl#/f-supp-3d/225/0274-01`; Unicode character offsets [25305:25494] (end exclusive); SHA-256 `7c9b8effe79b40465d8f54b688db37727be6b83430d03638ebb585ba402cc592`. Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged) Under Uribe, because possession with intent to distribute is a continuing offense, venue is proper along the way until the package arrives at its destination. Source: `docroot/ir/caselaw/f_supp_3d_225.jsonl#/f-supp-3d/225/0274-01`; Unicode character offsets [25495:25653] (end exclusive); SHA-256 `7c9b8effe79b40465d8f54b688db37727be6b83430d03638ebb585ba402cc592`. Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged) Venue as to Count 2 therefore was properly laid in New Jersey. Source: `docroot/ir/caselaw/f_supp_3d_225.jsonl#/f-supp-3d/225/0274-01`; Unicode character offsets [30790:30852] (end exclusive); SHA-256 `7c9b8effe79b40465d8f54b688db37727be6b83430d03638ebb585ba402cc592`. Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations

interpretation

Under Uribe, because possession with intent to distribute is a continuing offense, venue is proper along the way until the package arrives at its destination.

United States v. Tiangco — 225 F. Supp. 3d 274 (2016) · United States District Court for the District of New Jersey · 2016 (21usc841: author: Fable · historical QA: FIX (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)

Under Uribe, because possession with intent to distribute is a continuing offense, venue is proper along the way until the package arrives at its destination.

Source: docroot/ir/caselaw/f_supp_3d_225.jsonl#/f-supp-3d/225/0274-01; Unicode character offsets [25495:25653] (end exclusive); SHA-256 7c9b8effe79b40465d8f54b688db37727be6b83430d03638ebb585ba402cc592.