MCFADDEN, P. J., RAY and RICKMAN, JJ.
MCFADDEN, PRESIDING JUDGE.
Brown has filed three pro se appeals challenging his
convictions for multiple sexual offenses. The evidence is
sufficient to sustain those convictions. Brown complains that
his indictment was not returned in open court, but he did not
raise that argument in the trial court, so it is waived.
also contends, in multiple enumerations of error, that the
trial court lacked jurisdiction over him and was an improper
venue. He contends that he is not subject to the jurisdiction
of the courts of this state for crimes he committed in this
state. In other words, Brown is - or more accurately purports
to be - a "sovereign citizen." These arguments are
entirely without merit, and we take this opportunity to adopt
federal case law directing our trial courts to summarily
reject them, however presented.
briefs in all three appeals fail to comply with this
court's rules.Among other deficiencies, the briefs do not
contain succinct and accurate statements of the proceedings
below and the material facts, do not contain adequate
citations to the parts of the record or transcript essential
to a consideration of the alleged errors, do not state how
each enumerated error was preserved for consideration, and do
not state the applicable standards of review. See Court of
Appeals Rule 25. Brown's "pro se status does not
excuse him from compliance with the substantive and
procedural requirements of the law, including the rules of
this [c]ourt." Clemmons v. State, 340 Ga.App.
57, 58 (1) (796 S.E.2d 297) (2017) (citation omitted). These
rules "were created, not to provide an obstacle, but to
aid parties in presenting their arguments in a manner most
likely to be fully and efficiently comprehended by this
court." Orange v. State of Georgia, 319 Ga.App.
516, 517 (1) (736 S.E.2d 477) (2013) (punctuation omitted).
"While we will nonetheless review [Brown's] claims
of error to the extent we are able to ascertain them, he will
not be granted relief should we err in construing his
nonconforming appellate brief[s]." Clemmons,
supra. For reasons stated below, we affirm.
and procedural posture.
in the light most favorable to the verdicts, see Jackson
v. Virginia, 443 U.S. 307 (99 S.Ct. 2781, 61 L.Ed.2d
560) (1979), the evidence shows that Brown sexually assaulted
his minor daughter by licking her breasts and vagina, and by
inserting his penis into her mouth, vagina, and anus. The
jury found Brown guilty of rape, incest, three counts of
aggravated sodomy, and child molestation. The trial court
entered judgments of conviction, imposed sentences, and
denied Brown's motion for a new trial. He filed these
separate appeals, which have been consolidated for
consideration in this opinion.
contends that the indictment was not returned in open court.
But he has failed to point to any evidence supporting this
contention or that he objected to the indictment on this
specific ground before trial. "A demurrer to the
indictment, motion to quash or plea in abatement must be
entered before trial. [Brown] therefore waived this alleged
error by going to trial under the indictment without raising
the objection that the indictment was not returned in open
court." Thomas v. State, 331 Ga.App. 641,
655-656 (4) (771 S.E.2d 255) (2015) (citations and
punctuation omitted). Accord Peppers v. Balkcom, 218
Ga. 749, 750-751 (2) (b) (130 S.E.2d 709) (1963) (defendant
waived claim that indictment was not returned in open court
by failing to raise the issue before trial).
Jurisdiction and venue.
several different enumerations of error, Brown challenges his
convictions on the grounds that the trial court lacked
subject matter and personal jurisdiction, and was an improper
venue. The challenges are without merit.
is the policy of this state to exercise its jurisdiction over
crime and persons charged with the commission of crime to the
fullest extent allowable under, and consistent with, the
Constitution of this state and the Constitution of the United
States." OCGA § 17-2-1 (a). "Pursuant to this
policy a person shall be subject to prosecution in this state
for a crime which he commits, while either within or outside
the state, by his own conduct . . . if . . . [t]he crime is
committed either wholly or partly within the state[.]"
OCGA § 17-2-1 (b) (1). "The superior courts . . .
shall have exclusive jurisdiction over trials in felony
cases[.]" Ga. Const. 1983, Art. VI, Sec. IV, Para. I.
"Generally, a criminal action must be tried in the
county in which the crime was committed, and the [s]tate may
establish venue by whatever means of proof are available to
it, including direct and circumstantial evidence."
Borders v. State, 299 Ga.App. 100 (682 S.E.2d 148)
(2009) (citation omitted). See also Ga. Const. 1983, Art. VI,
Sec. II, Par. VI; OCGA § 17-2-2 (a).
case, it is undisputed that Brown's crimes took place in
Fulton County, Georgia, and that he was tried in Fulton
County Superior Court. "Consequently, [Brown] has failed
to demonstrate that his [convictions] are void for lack of
jurisdiction [or improper venue]." Goodrum v.
State, 259 Ga.App. 704 (578 S.E.2d 484) (2003).