Williams v. Commonwealth

PRESENT: Lemons, C.J., Goodwyn, Millette, Mims, McClanahan, and Powell, JJ., and Koontz, S.J. TONY WILLIAMS OPINION BY v. Record No. 141046 CHIEF JUSTICE DONALD W. LEMONS April 16, 2015 COMMONWEALTH OF VIRGINIA FROM THE COURT OF APPEALS OF VIRGINIA In this appeal, we consider whether the Court of Appeals erred by "inferring" that the trial court took judicial notice that the situs of an offense was within its territorial jurisdiction. We also consider under what circumstances an appellate court may properly take judicial notice of a fact not clearly noticed in the trial court. Finally, we…