Again, however, the issue was not explicitly addressed and Chapman was not cited. Thompson v. State, 277 Ga. 102 (3) ( 586 SE2d 231) (2003). Moreover, even if proof of the investigating officers' county of employment is sufficient to prove venue, in this case it is lacking.

The only other alleged evidence of venue consisted of the testimony of the four law enforcement officers who responded to the scene, each of whom stated that they were employed by the Liberty County Sheriff's Office. The issue in this case is directly controlled by the Supreme Court's ruling in Thompson v. State, 277 Ga. 102, 104 (3) ( 586 SE2d 231) (2003). In Thompson, the Supreme Court found the state's proof of venue insufficient as to a sexual battery count.

Powers, 309 Ga.App. at 264(1), 709 S.E.2d 821 (punctuation omitted); see also In the Interest of D.D., 287 Ga.App. 512, 514–15(2)(b), 651 S.E.2d 817 (2007) (“[T]he fact that the responding officers were employed by the Coweta County Sheriff's Department cannot serve as the exclusive proof that the crimes occurred in that county.”).See Thompson v. State, 277 Ga. 102, 103(1), 586 S.E.2d 231 (2003) (reversing Court of Appeals decision that found venue proper because Court of Appeals “relied upon evidence that was never presented to the jury in order to conclude that the evidence of venue was sufficient” and, by doing so, “failed to conduct a proper sufficiency review”).Bradley v. State, 238 Ga.App. 490, 490, 519 S.E.2d 261 (1999) (declining to take judicial notice of geographical facts to support venue and noting that there was no indication in the record that the trial court took judicial notice of same); accord Tunarka v. State, 247 Ga.App. 578, 579, 545 S.E.2d 15 (2001); seeOCGA § 24–2–1 (setting forth the proper procedure through which the trial court may take judicial notice of adjudicative facts).

(Punctuation and footnotes omitted.) Thompson v. State, 277 Ga. 102, 103 (1) ( 586 SE2d 231) (2003). Viewed in the light most favorable to the verdict, the evidence shows the following relevant facts.

Further, "because venue is an essential element of the State's case and must be decided by a jury, only evidence presented to the jury may be considered on appeal." Thompson v. State, 277 Ga. 102 ( 586 SE2d 231) (2003) (evidence showing that the act supporting child molestation charge occurred at residence and that the residence was in Houston County sufficient to prove venue). The evidence shows that the prosecution proved that the victim's neighbor lived in Douglas County, the officials who investigated the crime were employed by the Douglas County Sheriff's Department, employees of the Douglas County Department of Family and Children Services ("DFCS") were involved in the victim's case, the Douglas County Juvenile Court was involved in the proceedings, and a hospital report created by a nurse, detailing both the victim's and the investigator's statements, states that the victim's home where the molestation was alleged to have taken place was in Douglasville, Georgia, in Douglas County.

The standard of review on appeal to determine whether venue was sufficiently proved is the same as any other sufficiency review — whether, in the light most favorable to the prosecution, any rational trier of fact could have found venue beyond a reasonable doubt. Thompson v. State, 277 Ga. 102, 103 (1) ( 586 SE2d 231) (2003). This case was tried in Coweta County.

Boyd v. State , 306 Ga. 204, 207 (1), 830 S.E.2d 160 (2019) (citing Jackson v. Virginia , 443 U. S. 307, 319, 99 S.Ct. 2781, 61 L.Ed.2d 560 (1979), and Jones v. State , 304 Ga. 594, 598, 820 S.E.2d 696 (2018) ). "A criminal defendant may expressly authorize factual stipulations that will obviate the need for proof." Thompson v. State , 277 Ga. 102, 103-104 (2), 586 S.E.2d 231 (2003). In this case, the trial court read the written stipulation to the jury with no objection from either party, and though the stipulation was worded in the present tense, the purpose of the stipulation was clear – to eliminate "the necessity of further proof" of "the required element of conviction of a felony" for the felon-in-possession counts, as the jury was later instructed.

See OCGA § 40-6-6 (d) (1) (the driver of an emergency vehicle in pursuit of a suspected violator is authorized to disregard certain specified rules of the road; however, the statute does "not relieve the driver of . . . the duty to drive with due regard for the safety of all persons"). First, the policy alluded to was not presented to the jury and is not contained in the record on appeal. Accordingly, that material does not factor into our evidentiary review. See Thompson v. State, 277 Ga. 102 (1) ( 586 SE2d 231) (2003). Nonetheless, under OCGA § 40-6-6 (d) (2), when a law enforcement officer is pursuing a fleeing suspect in another vehicle and the suspect injures or kills any person during the pursuit, the "officer's pursuit shall not be the proximate cause or a contributing proximate cause of the damage, injury, or death . . . unless the law enforcement officer acted with reckless disregard for proper law enforcement procedures.

See Spaziano v. Florida, 468 U. S. 447, 454-456 ( 104 SC 3154, 82 LE2d 340) (1984) (precedent on lesser included offenses "does not require that the jury be tricked into believing that it has a choice of crimes for which to find the defendant guilty, if in reality there is no choice"). A criminal defendant may waive jurisdictional defenses, see Ramsey v. State, 267 Ga. App. 452, 453 ( 600 SE2d 399) (2004), and may expressly authorize factual stipulations that will obviate the need for proof, see Thompson v. State, 277 Ga. 102, 103-104 ( 586 SE2d 231) (2003). But the defendant cannot generally do so over the State's objection.

Id. at 903.Thompson v. State, 277 Ga. 102, 104 ( 586 SE2d 231) (2003). 2.