As part of its presentation of evidence, the State must prove venue, that is, the crime was committed in the jurisdiction of the court. Day v. State, 317 Ga. App. 243 (2012). All criminal cases must be tried in the county where the crime was committed. Article VI, Section II, Paragraph VI of the 1983 Georgia Constitution; O.C.G.A. § 17-2-2. A witness testifying to venue need not state that the county in which the incident occurred is in the state of Georgia. Cade v. State, 289 Ga. 805 (2011).
Proving that a crime took place within a city without also proving that the city is entirely within a county does not establish venue. Bizzard v. State, 312 Ga. App. 185 (2011); Graham v. State, 275 Ga. 290 (2002).
If a crime is committed on or immediately adjacent to the boundary line between two counties, the crime will be considered as having been committed in either county. Morey v. State, 312 Ga. App. 678 (2011); O.C.G.A. § 17-2-2. If it cannot be determined in which county a crime was committed, it shall be considered to have been committed in any county in which the evidence shows beyond a reasonable doubt it may have been committed. Rogers v. State, 290 Ga. 401 (2012).
The State may use both direct and circumstantial evidence to prove venue. Alexis v. State, 313 Ga. App. 283 (2011); Bruce v. State, 252 Ga. App. 494 (2001).
Public officials are believed to have performed their duties properly, and not to have exceeded their jurisdiction unless clearly proven otherwise. Taylor v. State, 315 Ga. App. 687 (2012); Brinson v. State, 289 Ga. 150 (2011).