Kopp: Venue for failing to register as sex offender also lies in state where travel began

In U.S. v. Kopp, No. 14-12408 (Feb. 18, 2015), the Court affirmed (1) the denial of a motion to dismiss an indictment for improper venue, and (2) the sentence imposed following the revocation of supervised release. Kopp moved from Georgia to Florida, where he failed to register as a sex offender. He was convicted of this offense in Georgia, where he preserved the argument that venue should have been in Florida, not in Georgia. Rejecting this argument, the Court pointed out that venue for this offense could be in “any district” where the crime was “begun, continued, or completed.” Here, Kopp began his crime in Georgia, because his interstate journey started there. The Court also affirmed the imposition of a six-month upward variance on Kopp’s sentence for subsequently violating his supervised release, pointing to Kopp’s “long and violent history of crime.”