Worthen v. GeorgiaAnnotate this Case
Appellant Trevis Worthen was convicted of malice murder and other crimes in connection with the shooting death of Tanieshia Evans. On appeal, he argued the trial court improperly purported to merge his felony murder counts into his malice murder conviction, when they actually were vacated by operation of law. The Georgia Supreme Court concluded this was true, but the error was harmless. Furthermore, Worthen argued the State failed to prove venue for most of the crimes. That, the Supreme Court concluded, was not true – particularly because the Court decided to overrule Division 3 of Jones v. Georgia, 537 SE2d 80 (2000), and to restore the authority of juries to make reasonable inferences regarding whether a location shown to be in a county is close enough to a crime scene to find that the crime was committed in the same county.