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Taylor v. State

Evidence that the defendant had broken into the victim's house two years prior to the kidnapping and aggravated sodomy was admissible to show the relationship between the defendant and the victim, and the State was not required to show that there were similarities between the prior difficulties and the present crimes.

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After a jury trial, Montrellus Lamar Taylor was convicted of kidnapping and aggravated sodomy. He appeals, arguing that the state failed to prove venue for the aggravated sodomy; that the trial court committed plain error when it instructed the jury on venue; and that the trial court improperly admitted evidence that Taylor previously had broken into the victim’s home. We find that the state adequately proved venue and that the trial court’s instruction on venue was correct. We also find that the trial court did not abuse his discretion in admitting the prior difficulties evidence. We therefore affirm Taylor’s convictions.

Viewed in the light most favorable to the verdict, Morris v. State, 322 Ga. App. 682, 683 1 746 SE2d 162 2013, the evidence shows that the victim dated Taylor, off and on, for a number of years, and they have two children together. Their romantic relationship ended in 2005.

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