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Williams v. State

The undercover officers' testimony regarding three cocaine sales supported a finding of proper venue.

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Demerich Demond Williams was tried and convicted on three counts of selling cocaine and three counts of selling cocaine within a thousand feet of a publicly owned housing project. On appeal he contends that the State failed to prove venue. When a defendant pleads not guilty and stands for trial, the State must establish venue beyond a reasonable doubt. Jones v. State, 272 Ga. 900, 902 537 SE2d 80 2000. “The State may establish venue by whatever means of proof are available to it, and it may use both direct and circumstantial evidence.” Id. at 903. “As an appellate court, we view the evidence in a light most favorable to support the verdict and determine whether the evidence was sufficient to permit a rational trier of fact to find beyond a reasonable doubt that the crime was committed in the county where the defendant was indicted.” Chapman v. State. 275 Ga. 314, 317 565 SE2d 442 2002.

The charges against Williams arose out of three separate cocaine sales. Officer Jimmy Sanders of the Chambers County Sheriff’s Department testified that in August 2000, he came to be involved in narcotics investigations in neighboring Troup County. He testified that as a part of the investigation he made one undercover drug purchase from Williams on August 25 “in West Point, over around the housing authority, the projects.” He testified that the location was in Troup County and that he worked with officers from Troup County.

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