Is the crime of uttering a forged writing a single act crime?

MultiRegion, United States of America

The following excerpt is from United States v. Rodriguez, 465 F.2d 5 (2nd Cir. 1972):

An analysis of the factual nature of the offense similarly supports the conclusion that it is a "single act crime." Offering the forged writing is the single unequivocal act which completes the offense. Of course, the fact that a crime is "completed" within one district does not necessarily mean that it cannot be "continued" in other districts. Cf., United States v. Cores, 356 U.S. 405, 78 S.Ct. 875, 2 L.Ed.2d 873 (1958). In certain circumstances a court may find an offense to be continuing though it was completed in one district if the relevant statutes support such a conclusion and if the result is consistent with the policies upon which the venue statutes are based. Cf., Cores, supra. Here, a holding that the crime of uttering a forged writing can be considered a continuing offense would be at odds with the protections afforded by the venue statutes. As was said in United States v. Peoni, supra, 100 F.2d at 403 (a case in which a defendant's conviction as an accessory to the possession of counterfeit bills by a remote vendee was reversed):

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