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County. It is well settled that ‘[a] defendant may stipulate to venue ..., but the record must reflect that the defendant expressly authorized such stipulation and that the stipulation was intended to obviate the need for direct proof.’ Tompkins v. State, 278 Ga. 857, 857(1), 607 S.E.2d 891 (2005). Nothing in the record indicates that A.A.’s counsel intended her statements to be a stipulation of venue or that A.A. authorized such a stipulation.” State v. Hasson, 334 Ga.App. 1, 778 S.E.2d 15 (September 24, 2015). In prosecution for DUI and related offenses, trial court erred by considering defendant’s challenge to venue in a pretrial motion. Defendant filed a pretrial motion contending that the incident occurred in Fulton County, rather than Dekalb County; “Hasson’s motion functions as a substantive challenge as to whether the State can meet its burden of proving venue, and his motion seeks to transfer venue on that basis.” But “‘[w]hether venue has been sufficiently proved is an issue for the jury to determine.’ (Footnote omitted; emphasis supplied.) Graham v. State, 275 Ga. 290, 292(2), 565 S.E.2d 467 (2002).” Thus, pretrial determination by the court was inappropriate. Freeman v. State, 333 Ga.App. 6, 775 S.E.2d 258 (July 9, 2015). Convictions for cruelty to children affirmed; evidence supported finding of venue. “Here, the evidence showed that Freeman and Outler moved with their children to an apartment in Clayton County in April 2009 and that they were the children's sole caretakers. And Dr. Messner testified that, because the bone fractures identified in E.F. and O.F. were in the ‘healing phase,” they must have occurred at least one to two weeks in the past and at most “a few months’ in the past. Thus, there was evidence to support the jury's conclusion that the children's injuries occurred in Clayton County. See Glenn v. State, 278 Ga. 291, 295–296(2) (602 S.E.2d 577) (2004) ( medical evidence as to when the child's injury most likely occurred, along with evidence as to where the child was staying at the time, provided sufficient evidence of venue as to conviction for cruelty to children ).” McDonald v. State, 296 Ga. 643, 770 S.E.2d 6 (March 2, 2015). Malice murder and related convictions affirmed; no ineffective assistance in failing to challenge venue where defendant was shot “on the Seminole County, Georgia side of the Highway 91 bridge,” but her body was found in Florida. “See OCGA § 17–2–3 (where crime committed on boundary line with another state, State of Georgia shall have jurisdiction unless other state makes a demand for the accused as a fugitive from justice); § 17–2–2(c) (criminal homicide shall be considered to have been committed in the county where cause of death inflicted); see also Tankersley v. State, 261 Ga. 318(8) (404 S.E.2d 564) (1991) (where victim was shot and drowned, venue proper in county in which victim was shot because shooting, if not the cause of death, directly and materially contributed to the subsequent cause of death).” Jones v. State, 329 Ga.App. 439, 765 S.E.2d 639 (October 30, 2014). Convictions for aggravated battery and related offenses affirmed; venue was sufficiently established for traffic offenses in Athens-Clarke County despite police chase that also went into Madison and Jackson Counties. “‘[V]enue for a crime involving a vehicle may lie in any county through which the vehicle traveled.’ (Punctuation and footnotes omitted.) Short v. State, 276 Ga.App. 340, 342–343(1)(a), 623 S.E.2d 195 (2005). See OCGA § 17–2–2(b), (e), (h). Accordingly, because there was testimony that Jones' vehicle traveled in Athens–Clarke County during the course of the police chase, there was sufficient evidence for the jury to find that venue was proper in that county. See id.” State v. Robertson, 329 Ga.App. 182, 764 S.E.2d 427 (October 2, 2014). Physical precedent only. Following defendant’s convictions for rape and aggravated sodomy, trial court properly granted motion for new trial based on State’s failure to prove venue. Defendant assaulted victim after she accepted his offer of a ride in Cobb County, and traveled to Turner Field in Atlanta – but no evidence showed that they ever entered Fulton County, where trial was held. Evidence showed that Cobb and Fulton Counties border, but “the State did not show that if Robertson drove into Atlanta, he necessarily also crossed the border between Fulton County and Cobb County.” Since the evidence didn’t show beyond a reasonable doubt that defendant and victim ever entered Fulton County, the State couldn’t rely on OCGA § 17-2-2(h) regarding cases where venue is uncertain. Perera v. State, 295 Ga. 880, 763 S.E.2d 687 (September 22, 2014). Murder and related convictions affirmed; trial court properly denied co-defendants’ motions to sever. Perera’s jailhouse letters to co-defendant Alma, attempting to coordinate their stories, were admissible against both as statements of a co-conspirator; pawning of victim’s DVD player by Alma didn’t require severance, “[g]iven the extensive nature of the evidence tying Perera to Burdette's murder, including all of the items found in Perera's home.” Stockard v. State, 327 Ga.App. 184, 761 S.E.2d 351 (March 26, 2014). Conviction for false statements reversed; evidence
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