Bowers (Christopher) v. State

and/or text messages originated in Washoe County or Nevada. Bowers waived his ability to challenge the venue by pleading guilty. See id. Even assuming, without deciding, that proof of the situs of the crime implicates the district court's subject matter jurisdiction and is thus not subject to waiver by entry of the guilty plea, compare e.g., Rothchild v. State,

558 So. 2d 981, 984

(Ala. Crim. App. 1989) (State must prove that felony was committed in the state to establish subject matter jurisdiction), with State v. Adams, 958 A.2d 295, 300 n.4 (Md. 2008) (whether an offense was committed within…