 But , Bollman held that venue for the Neutrality Act charges was improper in the District of Columbia . First , the Court rejected locus delicti venue ( without reaching the question of whether such could exist outside of a U.S. state ) . " [ T ] hat no part of this crime was committed in the district of Columbia is apparent . It is therefore the unanimous opinion of the court that they cannot be tried in this district . " Second , the Court rejected statutory venue under section 8 the Crimes Act of 1790 ( as permitted by Article Three for crimes not committed within a state ) . The Court held that the Territory of Orleans was not a place that triggered the alternative venue provisions of the Crimes Act . The Court held that the statutory term " any place out of the jurisdiction of any particular state " applied only to " any river , haven , bason or bay , not within the jurisdiction of any particular state , " and only in " those cases there is no court which has particular cognizance of the crime . " 
