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State court of last resort · ST-VA-SC
Williams v. Commonwealth
No. 141046Supreme Court of Virginia
141046 Williams v. Commonwealth 04/16/2015 In a drug possession and distribution prosecution, the Court of Appeals erred by inferring that the trial court took judicial notice that the situs of the offense was…
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141046 Williams v. Commonwealth 04/16/2015 In a drug possession and distribution prosecution, the Court of Appeals erred by infer…
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- Supreme Court of Virginia
- First seen
- Oct 4, 2026
- Last entry
- Apr 16, 2015
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141046 Williams v. Commonwealth 04/16/2015 In a drug possession and distribution prosecution, the Court of Appeals erred by inferring that the trial court took judicial notice that the situs of the offense was within its territorial jurisdiction. The record does not clearly reflect that the trial court took judicial notice of the situs of the offense and, absent the taking of such judicial notice, the evidence was insufficient to prove venue. The judgment of the Court of Appeals is reversed. Because the error did not stem from evidentiary insufficiency with respect to the guilt or innocence of the defendant, the case is remanded for a new trial, if the Commonwealth be so advised.
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