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Watson v. State

Venue in Fulton county was appropriate, since the victim's body was found there and the evidence did not readily show where she was killed.

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Defendant James Lamar Watson, Jr. was convicted of malice murder in connection with the death of his wife, Beverley Watson.1 He appeals, asserting, inter alia, the trial court erred in admitting, under the necessity exception to the hearsay rule, statements which Beverley made before her death to several friends and a police officer. We find no error and affirm. Viewing the evidence in a light favorable to the verdict, we find the following: Defendant and Beverley were married in 1983. They lived in Fayette County with two children, Ashley and Todd, who were born in 1984 and 1990, respectively. The Watsons had a stormy, often violent relationship. Defendant was known to stalk Beverley. He telephoned her constantly, and often visited her at work unannounced. On at least one occasion, he threatened her with a shotgun; on another, when Beverley came home with a friend, he threw her against a wall. In 1994 the parties separated and defendant was placed under a restraining order pursuant to divorce proceedings initiated by Beverley. He violated the order by entering Beverley’s home, refusing to leave, and physically abusing Beverley. Nevertheless, the Watsons reconciled.

Defendant, who had nine years of law enforcement experience and police academy training, continued to abuse Beverley even after they reconciled. In 1996 defendant and Beverley again discussed a separation. By early January, 1997, Beverley decided to move out of the house and leave defendant. She brought boxes home to prepare for the move. Defendant was aware of Beverley’s plan.

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