☢ test - Í

above (street location, investigating agency insufficient). Accord, Martin (November 2, 2015), above. Criticized, O’Donnell v. Smith , 294 Ga. 307, 751 S.E.2d 324 (November 18, 2013) (Nahmias, concurring). Bradley v. State, 272 Ga. 740, 533 S.E.2d 727 (September 11, 2000). Murder and related convictions affirmed, but robbery and hijacking convictions reversed based on lack of venue. 1. Defendants hijacked defendant’s car at gunpoint in Greene County, made victim drive to Morgan County, where they shot her and left her by the roadside to die. All charges were prosecuted in Morgan County. “The victim lost ‘complete dominion’ over her vehicle in Greene County when she was forced to transfer possession of it to her attackers. It is of no consequence that she continued as driver because she was compelled at gunpoint to follow her attackers’ orders and was not acting freely and voluntarily. Both the offense of armed robbery and hijacking of a motor vehicle were complete in Greene County.” 2. Venue for felony murder was correct in Morgan County, even though the underlying felony, kidnapping, was complete in Greene County, “because the victim was under the continuous control of the defendant until she was killed; thus, the murder was within the res gestae of the kidnapping. Lee v. State, 270 Ga. 798, 801(4), 514 S.E.2d 1 (1999).” Brannon v. State, 243 Ga.App. 28, 530 S.E.2d 761 (March 9, 2000). “In a RICO prosecution, venue is proper ‘in any county in which an incident of racketeering occurred.’ OCGA § 16-14-11; [cit.] Four of the predicate acts charged against Brannon were telephone calls to [co-conspirator] Stamps’ residence in Douglas County, thus establishing venue in Douglas County. Moreover, one of the drug-related predicate acts was that Brannon aided and abetted the Stampses’ distribution of marijuana in Douglas County…. [W]hen a defendant aids and abets the distribution of drugs in a particular county, venue is proper in that county, even though the defendant may not personally have distributed drugs there. [Cit.] Because the State presented sufficient evidence that Brannon committed one or more predicate acts in Douglas County, the State properly prosecuted him there.” Starling v. State, 242 Ga.App. 685, 530 S.E.2d 757 (March 9, 2000). DUI conviction reversed; evidence didn’t support finding of venue where deputy testified that traffic stop was made on his way to work. “Since he was not yet on duty, no inference could be made that the officer was acting within the territorial jurisdiction of his office. [Cits.] The record is devoid of any evidence showing that the officer's route to work fell strictly within Monroe County.” Hendrix v. State, 242 Ga.App. 678, 530 S.E.2d 804 (March 9, 2000). Aggravated battery conviction affirmed; evidence allowed finding of venue in Chatham County where beating took place in car traveling on I-16. “This Court may take judicial notice of the statutorily mandated official state highway map. Jordan v. State, 212 Ga. 337, 340(1), 92 S.E.2d 528 (1956) (former Ga.Code Ann. § 95-1608; see OCGA §§ 32-4-1; 32-4-2). The official state highway map shows that Highway 16 originates in Savannah in Chatham County, then proceeds through Effingham, Bryan, and Bulloch Counties, and beyond.” “[I]f a crime is committed in a car traveling within the state, ‘and it cannot readily be determined in which county the crime was committed, the crime shall be considered as having been committed in any county in which the crime could have been committed through which the railroad car, vehicle, watercraft, or aircraft has traveled.’ OCGA § 17-2-2(e). This crime occurred in a car traveling across several counties and continued as the car headed ‘back into town,’ i.e., Savannah and Chatham County. It cannot precisely be determined in which county or counties the beating occurred. But, the evidence shows beyond a reasonable doubt that the crime might have been committed in Chatham County.” In re: N.T.S., 242 Ga.App. 109, 528 S.E.2d 876 (January 28, 2000). Physical precedent only. Adjudication of delinquency reversed based on lack of evidence to establish venue. “The testimony relating to Revis Street, which failed to specify either the municipality or the county in which the street was located, is not sufficient to establish venue. Bradley v. State, 238 Ga.App. 490, 519 S.E.2d 261 (1999); Patterson v. State, 157 Ga.App. 233, 234, 276 S.E.2d 900 (1981). And while the trier of fact was entitled to infer that the officer acted within his territorial jurisdiction of the city of LaGrange, Joiner v. State, 231 Ga.App. 61, 62, 497 S.E.2d 642 (1998), and the trial court could have taken judicial notice that LaGrange was located in Troup County, nothing in the record indicates that the trial court took such judicial notice and gave the parties an opportunity to respond. Graves v. State, [269 Ga. 772, 504 S.E.2d 679 (1998)]; Bradley v. State, supra. Therefore, the State failed to establish venue beyond a reasonable doubt in the Juvenile Court of Troup County.” Accord, In re: J.E. , 245 Ga.App. 770, 538 S.E.2d 852 (September 1, 2000) (delinquency finding reversed; no evidence established, and court didn’t take judicial notice, that Peachtree City, where victim testified offense occurred, is in Fayette County). Jordan v. State, 242 Ga.App. 547, 528 S.E.2d 858 (January 27, 2000). Evidence was sufficient to support finding of venue in defendant’s forgery convictions. Defendant forged checks taken from her employer, whose office was in Dekalb County, where the prosecution lay. “It is entirely reasonable that evidence that a forged instrument was forged in a