State v. Zimmer
Kansas Supreme Court
426 P.2d 267 (1967)
Relevant factsFree
William Frederick Zimmer (defendant) was convicted of first-degree kidnapping and first-degree murder and sentenced to death. The victim was abducted in Shawnee County; she was last seen alive, and her body was found, in neighboring Pottawatomie County, about a five-minute drive away. Zimmer moved for a new trial, arguing venue for the murder charge was never properly established in Shawnee County, where he was tried. The motion was denied, and he appealed.
IssueFree
Whether a defendant charged with felony murder may be tried in the county where the underlying felony was committed, rather than only in the county where the killing itself occurred.