Subsequent Congresses have seen a number of proposals to expand venue for the trial of various federal criminal offenses. It is found in H.R. 970 / S. 155 (§207), S. 1968 (§8), H.R. In what seems to be the only federal appellate decision to address the question, the Fourth Circuit concluded that its earlier approval of venue under section 1513 in the district where the official proceeding had been, were being or would be held "cannot be reconciled with the Supreme Court's later decisions in Cabrales and Rodriguez-Moreno . Several bills—e.g., H.R. 1279 (as passed the House) (§106)—proposed a new federal crime, one that would have prohibited the commission of a crime of violence "during and in relation" to a drug trafficking offense, proposed 21 U.S.C. "Where a crime consists of distinct parts which have different localities, the whole may be tried where any part can be proved to have been done," 526 U.S. at 281. False Statements in Passport Applications

H.R. Similar provisions were found in S. 2611 (§208), as passed by the Senate, S. 2612 (§208), and S. 2454 (§208). Runaway Spouses

H.R. 228A(a). Trial in Emergency Conditions

In emergency conditions and with the consent of the accused, P.L. Comparable proposals appeared in H.R. 4682 (§705), S. 2356 (§2), S. 2361 (§101), and S. 3875 (§1402).
Venue, the place where federal criminal trials may be held, is a matter of constitutional and statutory law. Several proposals in the 109th Congress would have expanded federal venue. The Supreme Court's recent decisions in Cabrales and Rodriguez-Moreno suggest that a few of the proposals might have been more limited than their terms might indicate. The proposals dealt with venue in cases involving capital offenses, obstruction of justice, violent crime, drug trafficking offenses, false statements, failure to pay spousal support, wartime procurement fraud, and trial in emergency conditions. They appeared in H.R. 229, H.R. 970, H.R. 1279, H.R. 1751, H.R. 4437, H.R. 4472, S. 12, S. 155, S. 1968, S. 2356, S. 2361, S. 2454, S. 2611, S. 2612. S. 2767, and S. 3875.
Related reports include CRS Report RL33223, Venue: A Legal Analysis of Where a Federal Crime May Be Tried, by [author name scrubbed], which is available in abbreviated form as CRS Report RS22361, Venue: A Brief Look at Federal Law Governing Where a Federal Crime May Be Tried, by [author name scrubbed].