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Chase v. State

The jury was authorized to find beyond a reasonable doubt that the defendant might have committed the offense for which he was being tried in Catoosa County, and proof of venue was, therefore, sufficient.

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William Clifford Chase, Jr. was convicted in Catoosa County of impersonating a law enforcement officer. He appeals, challenging the sufficiency of the evidence supporting venue. He also argues that the trial court erred in admitting certain evidence at trial. For reasons that follow, we affirm.

1. When reviewing the sufficiency of the evidence as to venue, we must view the evidence in the light most favorable to the verdict and inquire whether the evidence would authorize a rational trier of fact to find beyond a reasonable doubt that venue was properly laid.1 So viewed, the evidence shows that in October 2012, a captain with the Catoosa County Sheriff’s Office received a request to approve a LeadsOnline account for an individual claiming to be a Catoosa County sheriff’s office employee. LeadsOnline is a database service used by law enforcement officers to determine whether items sold at pawn shops are stolen. Because the database contains sensitive personal information including names, birth dates, addresses, and social security numbers of people selling to pawn shops, the service is not available to the general public. Only approved law enforcement personnel with LeadsOnline accounts and passwords have authority to access the database.

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