One drug conspirator drives through Virginia, the rest can be tried in Virginia

In U.S. v. Mitchell, the Fourth Circuit in a per curiam opinion for the panel of Judges Niemeyer and Shedd and District Judge Wooten affirmed the defendant's conviction over his objection to venue, among other things, of which the Court said that the "acts of Mitchell and his co-conspirators in the Eastern District of Virginia were essential in fur-thering the drug conspiracy and were sufficient to establish venue on the drug conspiracy count. Mitchell engaged in a drug conspiracy that involved the sale of drugs in Washington, D.C., the transportation of those drugs through Virginia, and the distribution of the drugs in North Carolina. The transportation of the drugs through Virginia was an act in furtherance of the conspiracy and was essential to the distribution of those drugs in North Carolina."