Zachary Remijas

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The modern complexities of global interaction and accessibility have recently forced some federal courts to reconsider standards for determining proper venue for criminal defendants who commit offenses while engaged in transportation, particularly those involving interstate commerce and crimes spanning multiple districts. These courts’ application of two adversarial schools of statutory interpretation—textualism and intentionalism—has driven conflict between textualist jurisdictions adhering to the plain meaning of established constitutional and statutory sources, and intentionalist jurisdictions refraining from the “creeping absurdity” of establishing venue for certain in-transit offenses under the literal meaning of such provisions. This Note endorses the sensibility and superiority of the Ninth Circuit’s textualist approach to statutory interpretation in determining the proper venue for an in-flight assault in United States v. Lozoya. Specifically, this Note covers the significance of the Lozoya decision in exercising statutory interpretation that was faithful to well-settled traditions of venue law without heeding to the accessible but superficial understanding of 18 U.S.C. § 3237(a) that recently guided other federal circuit courts.