Liger v. State, 318 Ga. App. 373

Victim is Liger’s daughter, born in 1998.
Around 2005, Liger began sexually molesting her in the U.S. Virgin Islands, placing his penis in her vagina and on her anus.
In 2006 the victim moved to Georgia to live with her mother; Liger also moved and continued contact and molestation.
The victim resided with Liger at her aunt’s Paulding County home in December 2006; molestation continued there.
In 2008 the victim disclosed abuse; medical examination showed abnormalities and a forensic interview documented multiple assaults.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Venue proof for child molestation	Liger argues venue for the molestation charge was not proven.	Evidence showed offenses occurred in Paulding County; otherwise uncertain venue.	Venue proved beyond a reasonable doubt; Paulding County sufficient.
Due process and penetration instruction	Instruction allowed conviction for non-charged manner beyond indictment.	Instruction limited by indictment and properly stated law.	No due-process violation; charge cured by overall framing and indictment read to jury.

Brown v. State, 287 Ga. App. 857 (2007) (venue proof and reasonable-doubt standard for essential elements)
Hargrave v. State, 311 Ga. App. 852 (2011) (jury weighs venue evidence; any evidentiary support suffices)
Adams v. State, 312 Ga. App. 570 (2011) (due-process limits when misalignment between indictment and instruction; cure by charging)
Cardenas v. State, 282 Ga. App. 473 (2006) (continuing offenses; venue in one county supported by evidence of location)
Henry v. State, 274 Ga. App. 139 (2005) (victim's testimony establishing venue where offenses occurred)
Loyd v. State, 288 Ga. 481 (2011) (penetration definitions and sufficiency for rape charges)
Machado v. State, 300 Ga. App. 459 (2009) (indictment and charging accuracy affecting jury instructions)