California v. Beatty
Annotate this CaseA jury found defendant Roosevelt Beatty guilty of two counts of transporting methamphetamine, two counts of sale of methamphetamine, and two counts of possession of methamphetamine for sale. At a bifurcated proceeding, the trial court found that the prosecution proved various recidivist enhancements beyond a reasonable doubt. Defendant was sentenced to an aggregate determinate term of 16 years imprisonment. On appeal, defendant argued the judgment had to be reversed because the Yolo County Superior Court did not have jurisdiction over the charged offenses. In the published portion of its opinion, the Court of Appeal concluded Yolo County was a proper venue to try defendant. The Court found defendant aided and abetted a drug dealer by supplying drugs to the dealer for the purpose of selling the drugs to a third party who had contacted the dealer from Yolo County. The calls from Yolo County initiating the transactions provided the requisite preparatory acts or preparatory effects to establish venue.
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