Bradley v. State

Judge Harold R. Banke.

In a bench trial, James Russell Bradley was convicted of driving under the influence of alcohol and failure to maintain lane. In his sole enumeration of error, Bradley contests the sufficiency of the evidence. Among other claims, Bradley contends that the State failed to prove venue. Held:

Criminal actions must generally be tried in the county where the crime occurred. OCGA § 17-2-2 (a). When the evidence of venue does not conflict and no challenge to venue is made at trial, slight evidence suffices to prove venue. Minter v. State, 258 Ga. 629 (1) (373 SE2d 359) (1988).

The…