Jones v. the State

Summary

The Supreme Court of Georgia reversed Gary Jones's felony-murder and related convictions because the State failed to prove beyond a reasonable doubt that venue properly lay in Fulton County, holding that in every criminal trial the prosecution must establish venue beyond a reasonable doubt and disapproving the 'slight evidence' exception, which by its own terms can never apply once a defendant pleads not guilty. The court further held that the Double Jeopardy Clause does not bar retrial in a forum where venue is properly established, because venue is a neutral procedural matter bearing on neither guilt nor innocence. Chief Justice Benham, joined by Justice Hunstein, dissented, contending that witness testimony placing the crime scene on Evans Drive in Fulton County was sufficient for a rational jury to find venue proven.