☢ test - Í

Roundtree v. State, 270 Ga. 504, 511 S.E.2d 190 (February 8, 1999). “ A finding that pretrial publicity has so infected a community as to render it an inherently prejudiced venue is authorized only in extremely rare situations. Ross v. State, 268 Ga. 122, 123(1), 485 S.E.2d 780 (1997). Here, the record supports the trial court’s finding that the purportedly prejudicial publicity, which antedated Roundtree’s trial by a considerable number of months, was factual and balanced, rather than unnecessarily inflammatory and slanted. See Happoldt v. State, [267 Ga. 126, 128(2), 475 S.E.2d 627 (1996)]. Under these circumstances, the trial court did not abuse its discretion in denying Roundtree’s motion. Dixson v. State, [269 Ga. 898(2), 506 S.E.2d 128 (1998).] With regard to the alternative ground of actual prejudice, the record shows that only one-half of the prospective jurors was aware of the publicity and none expressed a fixed opinion as to Roundtree’s guilt based upon exposure to the media coverage. Under these circumstances, the trial court did not abuse its discretion in denying the motion for a change of venue on this alternative ground. See Dixson v. State, supra at 898(2), 506 S.E.2d 128; Jenkins v. State, 268 Ga. 468, 469(2), 491 S.E.2d 54 (1997).” Accord, McWhorter v. State , 271 Ga. 461, 519 S.E.2d 903 (September 13, 1999) (no change of venue required where “virtually all venire members were familiar with the case, [but] only five jurors wre excused for cause for having a fixed opinion about McWhorter’s guilt.”); Holmes v. State , 284 Ga. 330, 667 S.E.2d 71 (September 22, 2008) (newspaper article on evidentiary rulings, published day before trial, didn’t necessitate change of venue); Brown v. State , 284 Ga. 727, 670 S.E.2d 400 (November 3, 2008) (mere fact that “a significant percentage of prospective jurors” were excused for cause “failed to show that the pretrial publicity created an inherently prejudicial atmosphere or affected the remaining jurors' ability to be fair and impartial.”). B. PROOF OF Glispie v. State, 335 Ga.App. 177, 779 S.E.2d 767 (November 20, 2015). Physical precedent only. Convictions for possession of cocaine with intent to distribute, and related charges, affirmed, but conviction for stop sign violation reversed where “[n]o witness testified that the intersection of Avalon Boulevard and Ellington Road, where Glispie allegedly drove past a stop sign without stopping, was located in Rockdale County.” Cert. granted on different issue, case no. S16G0583, April 26, 2016. Twitty v. State, 298 Ga. 204, 779 S.E.2d 298 (November 2, 2015). Murder and related convictions reversed based on lack of proof of venue. Location of the killing at a certain boat ramp in a certain park wasn’t disputed, but no evidence established the county where the ramp was located. Victim’s body was found at a different location n in the same lake, in Richmond County, but “[t]he county in which a body is found, however, establishes venue for a homicide only when ‘it cannot be readily determined in what county the cause of death was inflicted.’ OCGA § 17–2–2(c).” “The State also points to evidence that Richmond County law enforcement officers undertook to investigate the killing of Mosley, and citing Chapman v. State, 275 Ga. 314, 317–318(4), 565 S.E.2d 442 (2002), the State argues that this evidence is some proof that the crime was committed in Richmond County. Even if evidence of the county in which an investigating officer is employed might be sufficient in some cases without more to establish venue, but see In re B.R., 289 Ga.App. 6, 9(2), 656 S.E.2d 172 (2007) (‘evidence of an investigating officer’s county of employment is insufficient standing alone to prove venue’), the evidence in this case that Richmond County officers were involved in the investigation is no evidence of the location in which the cause of death was inflicted, which is, of course, the relevant location for venue purposes. Here, the officers were not called to respond to that location, but instead to the separate location at which the body was found, which indisputably was in Richmond County. That Richmond County law enforcement officers would be involved in an investigation of the discovery of a body in Richmond County is unsurprising, and their involvement proves nothing about the location in which the cause of death was inflicted, especially when evidence shows clearly that the cause of death was inflicted somewhere other than the place in which the body was found.” Martin v. McLaughlin, 298 Ga. 44, 779 S.E.2d 294 (November 2, 2015). Habeas court properly denied relief from convictions for aggravated child molestation and related offenses; circumstantial evidence supported finding of venue. Overrules prior decisions holding “that a verdict must be sustained as to venue if there is ‘any evidence’ to support it. … We, however, disapproved that standard 15 years ago in Jones v. State, 272 Ga. 900, 903(2), 537 S.E.2d 80 (2000). … When reviewing the sufficiency of the evidence as to venue, an appellate court must view the evidence in the light most favorable to the verdict and inquire whether the evidence would authorize a rational trier of fact to find beyond a reasonable doubt that venue was properly laid. We disapprove the decisions of the Court of Appeals to the contrary.” In re: A.A., 334 Ga.App. 37, 778 S.E.2d 28 (September 28, 2015). Delinquency adjudication reversed; no evidence that offenses occurred in Spalding County. “[A]lthough A.A.’s counsel stated in summarizing the basis for the motion to suppress in her opening remarks that … ‘[a] juvenile was standing ... at Northside Hills apartment complex in Griffin, Spalding County,’ such a statement does not relieve the State of its burden to present evidence establishing beyond a reasonable doubt that the apartment complex where the alleged offenses occurred was in Spalding