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Taylor v. State

The evidence was sufficient to show venue in Bulloch County where the events that the confidential informant described were part of the Bulloch County drug operation about which the police officer testified, and the sale of crack cocaine to the defendant took place in Bulloch County as part of that operation.

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A Bulloch County jury found Terry Lavon Taylor guilty of one count of the sale of cocaine. Taylor appeals the denial of his motion for a new trial, arguing that because the State did not show that the crime occurred in Bulloch County, it failed to prove venue. For the reasons that follow, we affirm. The Georgia Constitution requires that venue in all criminal cases must be laid in the county in which the crime allegedly was committed.1 On appeal, we review a challenge to the sufficiency of the evidence of venue “in a light most favorable to support the verdict and determine whether the evidence was sufficient to permit a rational trier of fact to find beyond a reasonable doubt that the crime was committed in the county where the defendant was indicted.”2 “The State may establish venue by use of both direct and circumstantial evidence. Further, because venue is an essential element of the State’s case and must be decided by a jury, only evidence presented to the jury may be considered on appeal.”3

In the case sub judice, Officer Jody Stafford testified that at the time of the crime in question, she worked for the Statesboro Police Department as part of a special drug investigation unit targeting drug sales in Statesboro. During the direct examination of Stafford, the following exchange occurred: Q: All right. Now this particular operation where you go in and target and that sort of thing is that here in Bulloch County A: Yes.

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