Jones v. State
Supreme Court of Georgia
537 S.E.2d 80 (2000)
Gary Jones (defendant) shot and killed Jerry Zellner and Horace Lawson at a house where he had earlier bought crack cocaine, and Georgia (plaintiff) charged him with felony murder. Jones pled not guilty, putting venue in issue, but the only evidence at trial about the crime's location came from a neighbor who testified that his own home across the street from the victims' house was on Evans Drive in Fulton County — there was no direct evidence establishing that the victims' home itself was in Fulton County. The jury convicted Jones, and he appealed, arguing the state failed to prove venue in Fulton County beyond a reasonable doubt.
Whether evidence of venue must be established beyond a reasonable doubt.