State v. Clements
In State v. Clements, 175 W.Va. 463, 334 S.E.2d 600 (1985), the defendant, who was charged with the murder of two women, asserted that the State failed to prove that venue existed in Ohio County where he was indicted. He maintained that the State could not prove where the two women actually died.
In that case, the Court observed that the two women were last seen alive in Ohio County while the defendant's van was spotted later in Marshall County, and the women's bodies were found in Brooke County.
The Court further explained that the two girls were last seen at a Laundromat in Ohio County while the criminal scheme appeared to have started by removing the women to a more secluded spot.
Thus, the Court concluded that this was evidence that the intent to kill was formed in Ohio County. Since intent is a substantial element of murder, the Court held that the State adequately proved venue in Ohio County.