Bonner v. Commonwealth

I respectfully dissent and believe venue was proper in Brunswick County.

Application of Code § 19.2-244 requires a determination of where a specific crime was “committed.” This determination is straightforward when the crime is a discrete act. For example, rape is a discrete act which when completed constitutes the commission of the crime.

However, a crime committed in one jurisdiction may have a direct and immediate result in another jurisdiction. Gregory v. Commonwealth, 237 Va. 354, 355, 377 S.E.2d 405, 406 (1989); see also United States v. Blecker, 657 F.2d 629, 632 (4th Cir.1981)…