Abstract
“The friendly skies are not always so friendly.” This Note supports the Ninth Circuit’s en banc opinion in United States v. Lozoya, which determined that the landing district is the proper venue for prosecuting in-flight crime. The Ninth Circuit’s en banc ruling overturned the requirement to prosecute in-flight crimes in flyover districts, which created practical and evidentiary burdens for the prosecution and defense. The establishment of the landing district as the proper venue for in-flight crime prosecution promotes practical adjudication, justice for victims, constitutionally sound trials for defendants, uniformity for inflight prosecution, and encompasses Congress’s intent when enacting 18 U.S.C. § 3237(a).
Recommended Citation
Mikayla Gross,
Touchdown: Upholding Precedent for Proper Venue in United States v. Lozoya,
104 Neb. L. Rev. 829
(2026).
Available at: https://digitalcommons.unl.edu/nlr/vol104/iss4/5