United States v. Spivey, No. 18–4099 (4th Cir. 2020)
Nature of Case: Defendant was indicted in North Carolina federal court for failure to register as a sex offender after traveling from North Carolina to Colorado and not updating his registration. He sought to dismiss the indictment on the grounds of improper venue, as he was in Colorado. The trial court declined to dismiss the indictment, and the Defendant entered a conditional guilty plea reserving the right to appeal the motion to dismiss.
Holding: The 4th Circuit Court of Appeals affirmed the trial court. For a federal failure to register offense, venue can be proper the in district from which the individual departed.