REASONS FOR GRANTING THE WRIT
1. Assigning the exclusive determination of contested venue to the jury in the challenged locale fails to protect a defendant's fundamental rights under Article III and the Sixth Amendment
2. This case presents an additional Fifth and Sixth Amendment issue of national importance: whether venue, a fact necessary to the conviction in a criminal case, can be established by a mere preponderance of the evidence
Given that (as far as I know) there is no division among the circuit courts on these issues, a grant of cert is unlikely.