Cash v. State

Johnson, Presiding Judge.

Relying upon our holding in Culver v. State,1 we decided in this case that venue in a Medicaid fraud case brought pursuant to OCGA § 49-4-146.1 (b) (1) (C) was proper in the county in which the defendant submitted and the state processed the fraudulent claims.2

In State v. Kell,3 the Supreme Court reversed the decisions in Culver and Cash, holding that prosecutions for Medicaid fraud cases brought under OCGA § 49-4-146.1 (b) (1) (C) may be brought in any county in which an act in furtherance-of the crime took place. Thus, venue was proper not only in the county in…