What standard of review applies to a venue determination?

MultiRegion, United States of America

The following excerpt is from Gulf Ins. Co. v. Glasbrenner, 417 F.3d 353 (2nd Cir. 2005):

First, we consider the applicable standard of review. Gulf argues that our review should be de novo (as it is in reviewing criminal venue determinations, see, e.g., United States v. Geibel, 369 F.3d 682, 695 (2d Cir.2004)). The Glasbrenners advocate abuse of discretion.

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