Tunarka v. State

Blackburn, Chief Judge.

Following a bench trial, Jobe Tunarka appeals his convictions for possession of marijuana with intent to distribute and possession of less than one ounce of marijuana. Because the State failed to prove venue for these convictions, we must reverse.

Although Tunarka did not challenge venue at trial, he did plead not guilty to the crimes for which he was indicted. Tunarka contends that, as such, he validly challenged venue, and, in return, the State counters that it was required only to show slight evidence of venue and that such evidence was provided.

Contrary to the…