State v. Escue

William F. Escue 1 appeals from a conviction of robbery on the sole ground that the state failed to prove venue, ie., that the alleged crime took place in King County.

Appellant relies upon Const, art. 1, § 22 (amendment 10) which gives an accused the right to be tried in the county in which the offense allegedly occurred. There is insufficient evidence, appellant argues, to support the jury’s finding that the alleged robberies occurred in King County.

Proof of venue is necessary in a criminal prosecution, but it is not an element of the crime. State v. Hardamon, 29 Wn.2d 182, 186 P.2d 634…