After a bench trial, Davis was convicted of theft by taking based on a $350,000 loan he had promised to use to move a manufacturing plant to Georgia. The Court of Appeals held that the evidence supported an inference of fraudulent intent, but reversed the conviction because the State did not establish Dodge County as a proper venue: signing the contracts there did not establish venue when the money was wired to Davis’s metro-Atlanta account and there was no evidence that he exercised control over or spent it in Dodge County. The court upheld testimony about Davis’s precontract promise, explaining that the parol-evidence rule did not bar the evidence in this criminal prosecution, while declining to decide whether the rule could ever apply in a criminal case. It did not decide Davis’s challenge to his jury-trial waiver; it stated that, if retried, he could revoke the alleged waiver so long as doing so would not substantially delay or impede justice. The court affirmed in part and reversed in part, authorizing the State to retry Davis in a proper venue.