State v. Justin Darnay Graves
Court: Tennessee Court of Criminal Appeals Docket: W2024-01283-CCA-R3-CD Filed: March 19, 2026 County: Madison County Outcome: “Sale” counts reversed on venue; “delivery” counts affirmed
The Holding
A Madison County conviction was modified on appeal: the drug “sale” counts were reversed on venue grounds, while the “delivery” counts were affirmed. The Court of Criminal Appeals distinguished between the venue analysis for sale offenses and the venue analysis for delivery offenses in multi-county drug prosecutions.
Why It Matters
Tennessee drug prosecutions sometimes span multiple counties — a “sale” arranged in one county and a “delivery” completed in another. Graves holds that the venue analysis for these two offenses isn’t identical, and a court that aggregates them can convict on the wrong venue for one or the other.
If you are facing a multi-county Tennessee drug prosecution, your defense lawyer should be running each count through a separate venue analysis — sale, delivery, possession, conspiracy. Each has its own elements, and each has its own venue rules. Graves is the 2026 statewide authority for that distinction.
Statute / Rule References
Tenn. Code Ann. § 39-17-417 (sale, manufacture, delivery, or possession of controlled substance); venue rules under Tenn. R. Crim. P. 18
Read the Opinion
You can find the full opinion on the Tennessee Courts website. Search the [Tennessee Court of Criminal Appeals 2026 opinions index](https://www.tncourts.gov/courts/court-criminal-appeals/opinions) by docket number W2024-01283-CCA-R3-CD.
Charged with a Tennessee Criminal Case?
I’m Nathan Cate. I defend criminal cases in Davidson, Williamson, Rutherford, Sumner, Wilson, and Maury Counties. If your case touches the issues above — or any other Tennessee criminal matter — call (615) 664-8083 for a free consultation. I’ll review the charging document, run the procedural posture, and tell you what your case actually looks like.
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This is a summary of a published opinion, not legal advice. Holdings cited may evolve as later cases distinguish or overrule them. If you have a pending case that touches one of these issues, contact N. Cate Law for case-specific guidance.
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