State of Minnesota, Respondent, vs. Matthew Douglas Paulson, Appellant

Summary

The court held that the statutory requirement that a criminal case be tried in the county where the offense was committed is not an element of the offense. Because the factual basis established every substantive element of kidnapping to facilitate a felony and demonstrated substantive culpability, the guilty plea was accurate even though the factual basis did not establish venue. The court therefore affirmed the court of appeals.