Every criminal trial in the United States begins with a question that sounds procedural and is not: where. The Sixth Amendment promises a jury of the state and district where the crime was committed, and it also promises an impartial one. In most cases those two guarantees sit together without friction. In a serial case they collide. By the time a defendant charged with five or six or thirteen murders reaches arraignment, the community that is supposed to judge him has usually spent months reading about him, watching him on the evening news and talking about little else. Defense lawyers ask to move the trial. Prosecutors sometimes agree, sometimes fight, and sometimes ask for the move themselves. Judges weigh survey numbers, juror questionnaires and stacks of clippings, and appellate courts revisit the decision years later, when the verdict is already in.
These ten cases span half a century, from Houston in 1974 to Lubbock in 2009. In seven of them the trial left the county where the charges were filed. In two, a judge kept the case where it was filed, over strong objection, and the appellate courts let him. In one, a federal judge ruled that the jury pool had been poisoned and ordered a new trial, and the federal appeals court above him put the conviction back. Taken together they show how much of the work of a serial prosecution happens before a single juror is sworn.
The deaths that came to be called the Houston Mass Murders came to light in August 1973, after Elmer Wayne Henley Jr., a 17-year-old from the Houston Heights, called the Pasadena police to say he had shot Dean Corll. Henley was charged with six murders. His co-defendant, David Brooks, was charged with four. The deaths of 27 boys and young men came to light that August, and the story ran on front pages across Texas for months.
Henley’s case came before State District Judge William Hatten in Houston in January 1974. His lead lawyer, Will Gray, asked the court to throw out the statements the prosecution called confessions and to delay the trial for six months because of publicity. Gray did more than file a motion. He subpoenaed editors and news directors from newspapers and broadcasters in eight Texas cities and demanded their entire coverage of the case. He wanted to prove that no fair trial was possible anywhere in Texas, and he wanted to know how reporters had obtained a leaked copy of a statement in which Brooks implicated his client. Lawyers for the Houston Post and the Houston Chronicle came to court to fight the subpoenas, and the Post’s lawyer asked for an order protecting the paper’s sources.
What happened next was unusual. Late in January both sides agreed that Henley could not get a fair trial in Houston at that time. The prosecution called fifteen witnesses with no ties to law enforcement or the press, and ten of them said they did not believe a fair trial was possible in the city. Judge Hatten granted a continuance and, on his own motion, moved the trial out of Houston. Gray, having spent weeks arguing that the publicity was poisonous, opposed the move. "It would be fruitless to move the trial at this time," he said. His point was that the coverage had reached every county in the state, and that a change of address would change nothing.
The trial went to San Antonio. In July 1974 a jury there convicted Henley of six counts of murder, and he received six consecutive sentences of 99 years. The verdict came on July 16, 1974, according to a 2022 account in the Dallas Voice. The publicity followed the case to the other defendant. In November 1974, after a dispute between his court-appointed lawyers over an insanity plea, the prosecutor in Brooks’s case told the court that the coverage of Brooks had been just as intense as the coverage of Henley, and the judge moved toward a change of venue for him as well.
Henley’s 1974 convictions were reversed on appeal in December 1978. He was tried again in June 1979, convicted again on the six counts and sentenced to six life terms. He has been denied parole many times, most recently on November 7, 2025, when the Texas Board of Pardons and Paroles set his next review about ten years out.
Ted Bundy was charged in 1978 with the murders of two women in the Chi Omega case at Florida State University in Tallahassee, along with three counts of attempted murder and two of burglary. Leon County could not produce a jury that had not already formed an opinion. The trial was moved to Miami, where it opened on June 25, 1979, before Judge Edward Cowart. Television cameras were in the courtroom, and the trial became one of the first in the country to be broadcast nationally. Moving the case three hundred miles did nothing to shrink its audience. It enlarged it.
The jury convicted Bundy on July 24, 1979, after less than seven hours of deliberation, and Cowart sentenced him to death. On appeal Bundy argued, among many other things, that the pretrial hearings should have been closed to the public. The Florida Supreme Court rejected that claim when it affirmed the convictions on June 21, 1984, and it made a second point that runs through the law of venue. By asking for a change of venue, the court held, Bundy had given up his right to be tried in Leon County. A defendant who wins a transfer cannot later complain that the county he fled was the only one entitled to try him.
The second Florida case followed the same path. Bundy was indicted on July 21, 1978, for the kidnapping and murder of Kimberly Leach, 12, of Lake City, and the case was moved from Suwannee County to Orange County. The trial began in Orlando on January 7, 1980. By then the Miami verdict had been national news for months, and the problem was no longer whether jurors had heard of the defendant but whether they had heard of his first conviction. Of the twelve jurors seated in Orlando, three had not known about the Chi Omega case. The jury convicted him of murder, with other charges, and recommended death. The Florida Supreme Court affirmed on May 9, 1985. The Eleventh Circuit rejected his federal petition in 1988, and Bundy was executed at Florida State Prison in Starke on January 24, 1989.
Gerald Gallego was arraigned in Sacramento County on charges of kidnapping and murdering Craig Miller and Mary Beth Sowers in November 1980. The case was saturated with local coverage from the start, in part because his accomplice, Charlene Williams, had agreed to testify against him in exchange for a guilty plea to two murders and immunity in eight other killings across three states. In 1981 Gallego moved for a change of venue, pointing to the volume of reporting in the Sacramento press. The court granted the motion and sent the case to Contra Costa County, where it was heard by Superior Court Judge Norman Spellberg. Gallego represented himself at the guilt phase. In 1983 the Contra Costa jury convicted him of two counts of murder, with other charges, and sentenced him to death.
Nevada came next. Gallego was charged with the kidnapping and murder of Stacey Redican and Karen Chipman Twiggs, both 17, from the Sacramento area, whose deaths came to light near Lovelock, in rural Pershing County, in July 1980. He was arraigned in Lovelock on January 12, 1984. Here the venue question took a different form. Gallego was not a local figure in Pershing County, but the California trial had made him a regional one, and the case against him again turned on Williams. Jury selection began on May 14, 1984, after about four months of preparation. In June the Lovelock jury convicted him of two counts of first degree murder, with other charges, and sentenced him to death.
Both state supreme courts rejected his venue and publicity claims. The Nevada Supreme Court affirmed on December 20, 1985, writing that he had been fairly tried, convicted and sentenced. Five years later to the day, on December 20, 1990, the California Supreme Court rejected his challenge to the venue ruling along with his claims about the waiver of counsel and a list of other guilt-phase rulings. The Ninth Circuit, deciding his federal petition against the Nevada judgment on September 4, 1997, held that he had shown neither presumed nor actual prejudice from the publicity. It did set aside the Nevada death sentence, for a different reason: the jury had been misled about the possibility of clemency. A new Nevada jury sentenced him to death again in September 1999. He died of cancer in the prison medical center in Carson City on July 18, 2002, with his federal challenges still open. He was never executed.
No case on this list puts the venue problem in sharper relief than that of Marion Albert Pruett, because no other defendant did so much to create the publicity he later said had denied him a fair trial.
In 1979 Pruett was released from a 23-year federal sentence for bank robbery, apparently in exchange for testimony against an underworld figure, and placed in the Federal Witness Protection Program in New Mexico. Within two years five people were dead in four states, and he was convicted of every one of those killings. On October 12, 1981, Bobbie Jean Robertson was killed in Fort Smith, Arkansas. Sixteen days later, on October 28, 1981, Pruett held a televised press conference in a Mississippi jail and called himself a "mad dog killer." According to the Eighth Circuit, a videotape of the statement was played several times by nearly every local television station and many radio stations, and it became common to describe him as a "self-confessed mad-dog killer."
When Arkansas brought him to trial for Robertson’s death in the summer of 1982, the court moved the case out of Sebastian County because of the publicity. It did not move it far. The trial went to Van Buren, in neighboring Crawford County, which lies in the same judicial district and shares its newspapers and broadcast market. Pruett asked for a second change of venue, a new jury panel and more time. All three requests were denied. Jury selection showed how thin the remedy had been. The first panel ran out after five days; the first eleven jurors came from a 65-member panel, and eight more people from a supplemental panel were questioned before the twelfth was seated. Twenty-six prospective jurors were excused because they had formed opinions or knew about the case. Pruett used all his peremptory challenges and said he had to accept jurors he would otherwise have struck. On September 9, 1982, the jury convicted him of capital murder, and he was sentenced to death.
The Arkansas Supreme Court affirmed in 1984, upholding the change of venue to Crawford County and the refusal to grant a second one. That might have ended the matter. Instead the case spent nine years in federal court. In 1997 a federal district judge granted Pruett’s petition for habeas corpus. He held that pretrial publicity, together with the refusal of a second change of venue and a continuance, had denied Pruett a fair trial. He relied on numbers: 22 of 77 potential jurors, 29 percent, had said they probably could not be impartial, and eleven of the twelve seated jurors had some prior exposure to the facts. He vacated the conviction and the sentence and ordered Arkansas to release or retry Pruett within 120 days.
The Eighth Circuit reversed on August 7, 1998. Its opinion is one of the clearest statements on record of the line between a jury that knows about a case and a jury that has prejudged it. Pruett himself had invited much of the coverage, the court held. Most of it came in the weeks after Robertson’s death, roughly ten months before trial. The figures the district judge relied on did not show the deep and bitter prejudice needed to presume an unfair trial, and each juror had sworn to be impartial. The court quoted Pruett’s own trial lawyer, who had testified that he was "disappointed it was not as extensive as I had been afraid it would be." Then it wrote the sentence for which the case is remembered: "The accused is not entitled to an ignorant jury, just a fair one." The conviction and death sentence were reinstated, and Pruett was later executed in Arkansas at the age of 49.
Arthur Gary Bishop confessed in July 1983 to the deaths of five boys in the Salt Lake City area between 1979 and 1983. The confession came after weeks of local coverage of the last of the five cases, and the confession itself became the biggest story in the state. In January 1984 his lawyers moved to take the case out of Salt Lake County. They backed the motion with a survey of 400 county voters. Eighty percent of them believed Bishop was guilty, and 88 percent favored the death penalty if he were convicted.
The trial judge did something that has become common practice since. At the defense’s request he held the motion until after jury selection, so that the court could see whether a fair panel could in fact be seated. It could, he ruled, and he denied the motion. Six members of the jury panel said they had read or seen part of an article the court described as prejudicial. All but one were excused, and the one who stayed said she would decide the case on the evidence alone. The jury convicted Bishop of five counts of first-degree murder, with other charges, and in March 1984 returned verdicts of death on all five murder counts.
The Utah Supreme Court affirmed on February 3, 1988. It upheld the use of voter registration lists to summon jurors and the denial of a change of venue, holding that the publicity was not so extreme that prejudice could be presumed and that Bishop had not shown actual prejudice among the jurors chosen. The distinction between presumed and actual prejudice is the hinge on which nearly every case here turns. A survey can show that a community has an opinion. It cannot show that the twelve people in the box share it, and appellate courts have consistently looked at the twelve. Bishop ended his appeals that spring and was executed by lethal injection at the Utah State Prison in June 1988.
Richard Ramirez was arrested in East Los Angeles on August 31, 1985, the day after police released his photograph, and charged in a case that had dominated Southern California news for the entire summer. On July 21, 1986, the defense moved to take the trial out of Los Angeles County. The hearing lasted about two months, and the judge watched hours of videotaped news coverage. A survey of 300 eligible jurors, conducted in late November 1986, reported that 94.3 percent had heard of the case and 51.7 percent believed Ramirez was responsible.
On January 9, 1987, the court denied the motion. It called the coverage "saturation," a word defense lawyers normally have to fight for, and then held that saturation was not enough. Los Angeles County was so large and so varied, the court reasoned, that there was no reasonable likelihood Ramirez could not receive a fair trial there. The size of the county was the argument. A defendant in Lovelock or Van Buren draws from a few thousand households who read the same paper. A defendant in Los Angeles draws from millions.
Ramirez’s lawyers also challenged the jury pool itself, arguing that it underrepresented Hispanic residents. The court denied that motion on May 31, 1988, after the jury commissioner revised the master list, and jury selection began that summer. The defense asked as well for eight separate trials, which the court refused. Of the twelve jurors finally seated, one had never heard of the case, and the others knew it only in general terms and said they had formed no opinion. During deliberations one juror was killed in a crime unconnected to the trial, and Judge Michael Tynan seated an alternate. "We must get on with the task life has given us," he told the jury. On September 20, 1989, the jury convicted Ramirez on all 43 counts, including 12 counts of first degree murder and one of second degree murder. He was sentenced to death on November 7, 1989.
The California Supreme Court affirmed unanimously on August 7, 2006, rejecting his claims on the change of venue, the makeup of the jury pool, severance and a challenge to one juror, among others. The United States Supreme Court declined review in 2007. Ramirez died on death row on June 7, 2013, of complications of lymphoma, at 53.
Six years after Gallego’s trial left Sacramento, another Sacramento case followed. In November 1988 the deaths of several elderly tenants of Dorothea Puente came to light in Sacramento, and Puente was arrested in Los Angeles. On July 3, 1990, she was charged in Sacramento County Superior Court with nine counts of first-degree murder, with the special circumstance of multiple murder, which made the case eligible for the death penalty. She pleaded not guilty.
Puente’s case had been national news from its first week, and in Sacramento it had been the story of the decade. On February 19, 1992, a judge granted a change of venue, ruling that pretrial publicity in Sacramento had made a fair trial there impossible, and on July 9, 1992, the case was sent to Monterey County. Jury selection began in Monterey on November 2, 1992, and lasted about three months. The jury of eight men and four women then heard more than five months of testimony and received about 3,100 exhibits before Superior Court Judge Michael Virga.
The Monterey jury returned a split verdict on August 26, 1993. It convicted Puente of the first-degree murders of Dorothy Miller and Benjamin Fink and the second-degree murder of Leona Carpenter, and it could not reach verdicts on the other six counts, which were dismissed. It then deadlocked on the death penalty. On December 10, 1993, Puente was sentenced to life without the possibility of parole. Whether a Sacramento jury would have reached the same result is the kind of question a change of venue is designed to make unanswerable. She died in prison at Chowchilla on March 27, 2011, at 82, still denying that she had killed anyone.
In 1987 six young women and girls from the El Paso area were killed, and their deaths came to light in El Paso County between September 1987 and March 1988. David Leonard Wood was charged with capital murder under the Texas provision that makes it a capital crime to murder more than one person in the same scheme or course of conduct. The Associated Press reported that he was the first defendant prosecuted under it.
The El Paso coverage was relentless, and the case never came to trial there. Because of the publicity, the trial was moved to Dallas, more than 600 miles east, and the Texas Department of Criminal Justice still lists Dallas as the county of conviction. A Dallas jury convicted Wood of one count of capital murder in late November 1992 and sentenced him to death. He was received on death row on January 14, 1993.
Wood has always denied the killings, and his case is still open more than three decades later. His appeals were exhausted by 2008, but an execution set for August 20, 2009, was stayed the day before, and another set for March 2025 was stayed on March 11, 2025. On July 30, 2025, the Texas Court of Criminal Appeals sent the case back to the trial level to develop eight claims of innocence and unfair trial. On September 4, 2026, a visiting judge granted his request for new DNA testing. The judge who now hears the case sits in El Paso. The trial that was moved away from the city has, in its post-conviction life, come back to it.
Genene Jones, a licensed vocational nurse, went to work in August 1982 for a new pediatric practice in Kerrville, in the Texas Hill Country. On September 17, 1982, Chelsea McClellan, 15 months old, died after injections Jones gave her. A Kerr County grand jury indicted Jones in 1983 for Chelsea’s murder and for injury to other children. Kerrville is a small town, and the case had divided it.
Because of publicity, the trial was moved from Kerr County to Georgetown, in Williamson County north of Austin. It opened in January 1984. The Kerr County district attorney, Ron Sutton, prosecuted the case in a borrowed courtroom before a jury that had never lived with it. After a five-week trial, the jury of seven women and five men deliberated four and a half hours and convicted Jones of murder. The next day it gave her 99 years, the maximum. The foreman, a Georgetown man, said the facts were "so overwhelming we could not ignore them." Her lawyers said they would appeal, arguing among other things that heavy press coverage had created a "circus atmosphere" around the trial. The Court of Appeals in Austin affirmed on August 13, 1986.
The move did not end Jones’s history in court. In October 1984 a Bexar County judge, hearing the case without a jury, convicted her of injury to a child, and sentenced her to 60 years. In 2017, as a 1977 mandatory release law was about to free her, Bexar County prosecutors indicted her in five more children’s deaths. On January 16, 2020, she pleaded guilty in San Antonio to the murder of Joshua Sawyer, 11 months old, and was sentenced to life. The other four charges were dismissed. An appeal was dismissed on August 25, 2021.
Levi King’s case required two changes of venue in two states for one week of violence. On September 29, 2005, Orlie and Dawn McCool were killed near Pineville, in McDonald County, Missouri. The next day, near Pampa, in Gray County, Texas, Brian Conrad, Michell Conrad and her son, Zach Doan, 14, were killed. King, a Missouri parolee, was arrested within days.
In Missouri, after the defense waived a preliminary hearing, the case was moved on a change of venue to Pulaski County, according to McDonald County Prosecutor Janice Durbin. Prosecutors announced in 2006 that they would seek death. On April 18, 2008, King pleaded guilty to two counts of first-degree murder under an agreement that removed the death penalty, and he received two consecutive terms of life without parole.
Texas did not offer the same bargain. A Gray County grand jury indicted King for capital murder in March 2006, and District Attorney Lynn Switzer filed notice that the state would seek death. State District Judge Stephen Emmert moved the trial from Gray County to Lubbock and issued a gag order. The trial opened at the Lubbock County Courthouse on September 3, 2009, and shortly after it began King pleaded guilty to all three counts of capital murder, knowing he could still be sentenced to death. The jury’s task changed from guilt to punishment. On October 6, 2009, after the Lubbock jury could not agree on the mitigation question, King received life without parole.
The law of venue rests on a distinction the Eighth Circuit put in eleven words: the accused is not entitled to an ignorant jury, just a fair one. Every court in these cases, trial and appellate, was asking the same practical question, which was not whether people had heard of the defendant but whether the twelve who sat in judgment had made up their minds before the first witness. When judges thought the answer in the original county was yes, they moved the trial, sometimes a county away, as in Van Buren, and sometimes across the state, as from El Paso to Dallas. When they thought the county was large enough to absorb the coverage, as in Los Angeles, or that careful questioning could filter it out, as in Salt Lake City, they kept the case where it was.
No appellate court in these ten cases overturned a conviction on venue grounds in the end. The closest was Pruett’s, where a federal judge held that publicity had denied a fair trial and the court above him disagreed. The appellate courts were consistent in looking past the survey numbers to the jurors themselves, and consistent in holding that a defendant who asks to move cannot later claim the old county as a right. What the transfers did change is harder to measure. Henley’s lawyer argued in 1974 that a new address would make no difference, because the coverage had reached everywhere. The Bundy jury in Orlando proved him partly right: nine of twelve already knew the first verdict. By the time of Levi King’s trial in 2009, a gag order in Lubbock was as much a part of the remedy as the move itself.
• August 1973: The Houston Mass Murders come to light; Elmer Wayne Henley Jr. is charged with six murders.
• January 1974: Judge William Hatten moves Henley’s trial out of Houston on his own motion after both sides agree a fair trial is not possible there.
• July 1974: A San Antonio jury convicts Henley of six counts of murder.
• November 1974: The prosecutor in David Brooks’s case tells the court the publicity has been as intense as in Henley’s; the judge moves toward a change of venue.
• June 1979: Henley is convicted again on retrial after the 1974 verdict is reversed in December 1978.
• June 25, 1979: Ted Bundy’s Chi Omega trial opens in Miami after a change of venue from Leon County.
• July 24, 1979: Bundy is convicted in Miami.
• January 7, 1980: Bundy’s trial in the Leach case opens in Orlando after a change of venue from Suwannee County.
• 1981: Gerald Gallego’s California case is moved from Sacramento County to Contra Costa County.
• October 28, 1981: Marion Albert Pruett calls himself a "mad dog killer" at a televised press conference in Mississippi.
• September 9, 1982: Pruett is convicted of capital murder in Van Buren, Crawford County, Arkansas, after a change of venue from Sebastian County.
• 1983: Gallego is convicted in Contra Costa County and sentenced to death.
• January 1984: Arthur Gary Bishop’s motion for a change of venue, backed by a survey of 400 voters, is denied after jury selection.
• January to February 1984: Genene Jones is tried in Georgetown after a change of venue from Kerr County; convicted of murder and sentenced to 99 years.
• March 1984: Bishop is sentenced to death.
• June 1984: Gallego is convicted in Lovelock, Nevada, and sentenced to death.
• June 21, 1984: The Florida Supreme Court holds that Bundy gave up his right to be tried in Leon County by asking for a change of venue.
• December 20, 1985: The Nevada Supreme Court rejects Gallego’s venue and publicity claims.
• January 9, 1987: The court denies Richard Ramirez’s motion to move his trial out of Los Angeles County.
• February 3, 1988: The Utah Supreme Court upholds the denial of Bishop’s change of venue.
• June 1988: Bishop is executed.
• January 24, 1989: Bundy is executed.
• September 20, 1989: Ramirez is convicted on all 43 counts.
• December 20, 1990: The California Supreme Court rejects Gallego’s challenge to the venue ruling.
• February 19, 1992: A change of venue is granted in Dorothea Puente’s case; the case is sent to Monterey County on July 9, 1992.
• November 1992: A Dallas jury convicts David Leonard Wood of capital murder after a change of venue from El Paso.
• August 26, 1993: The Monterey County jury convicts Puente of three murders and deadlocks on six other counts.
• 1997: A federal district court grants Pruett habeas relief on publicity and venue grounds.
• September 4, 1997: The Ninth Circuit holds Gallego showed no presumed or actual prejudice from publicity.
• August 7, 1998: The Eighth Circuit reverses in Pruett’s case: "The accused is not entitled to an ignorant jury, just a fair one."
• August 7, 2006: The California Supreme Court affirms Ramirez’s convictions, rejecting his venue claim.
• April 18, 2008: Levi King pleads guilty in Missouri after a change of venue to Pulaski County.
• September 3, 2009: King pleads guilty to three counts of capital murder in Lubbock after a change of venue from Gray County.
• October 6, 2009: King receives life without parole.
• January 16, 2020: Jones pleads guilty in Bexar County to the murder of Joshua Sawyer.
• November 7, 2025: Henley is denied parole.
• September 4, 2026: A visiting judge grants Wood’s request for new DNA testing.