The State v. Kell; the State v. Cash

Summary

The court held that venue for Medicaid fraud committed through a fraudulent scheme or device lies in any county where an act in furtherance of the scheme occurred. Because acts supporting both prosecutions occurred in the counties where the defendants were tried, the court reversed the Court of Appeals' venue rulings. The court also explained that prior discussions of venue in related decisions were dicta and did not control the issue.