It is true that jurisdictional errors are not waived, because they affect the basic authority of a court to hear and decide a case. Venue is not jurisdictional, however. This Court has so held in the civil context. See Rutland Ry. We should not think about it in the metaphysical terms which have often been associated with considerations of jurisdiction.
Venue is a concept of convenience.
Authorities outside this Circuit support the principle that venue is non-jurisdictional in the criminal context as well. We agree that venue is subject to waiver in a criminal case. 20 expressly permits written waiver of venue by a criminal defendant, which would be impermissible if venue were a jurisdictional limitation. For the reasons stated above, we conclude that Calderon's objection to venue was waived by his guilty plea. We therefore affirm the judgment of conviction.