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U.S. v. Holcombe

SORNA Registration Violation Case's Proper Venue in SDNY Is Explained

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*1 Thomas Abdul Holcombe appeals from a judgment of conviction entered after a bench trial in the United States District Court for the Southern District of New York (Briccetti, J.) for failing to register as a sex offender, in violation of the Sex Offender Registration and Notification Act (“SORNA”), 18 U.S.C. §2250(a). On appeal, Holcombe argues principally that venue was improper in the Southern District of New York and that SORNA’s registration requirements are void for vagueness and violate his right to travel. We AFFIRM.*2

RAYMOND LOHIER, C.J.Thomas Abdul Holcombe, a sex offender subject to the requirements of the Sex Offender Registration and Notification Act (SORNA or the Act), was convicted after a bench trial in the United States District Court for the Southern District of New York (Briccetti, J.) of failing to update his registration when he moved from New York to Maryland. SORNA makes it a crime for a sex offender who is required to register under the Act and who “travels in interstate…commerce” to “knowingly fail[] to register or update a registration as required by [the Act].” 18 U.S.C. §2250(a). The statute governing venue for crimes committed in more than one district, 18 U.S.C. §3237(a), provides that “any offense against the United States begun in one district and completed in another, or committed in more than one district, may be…prosecuted in any district in which such offense was begun, continued, or completed.” The principal

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