or both the county where the death occurred and the county where the injury occurred. 58 A.L.R.5th 535, 599-607. The first category of states looks to the county where death occurred. These states focus on the fact that wrongful death actions do not arise until there has been a death. Department of Transportation v. Evans, 269 Ga. 400, 499 S.E.2d 321 (1998) (affirming the appellate court decision in Evans v. Dept. of Transp., 226 Ga. App. 74, 75,485 S.E.2d 243 [1997]); Wentz v. Montana Power Co., 280 Mont. 14, 19, 928 P.2d 237 (1996); Gabriel v. School Dist. #4, Libby, 264 Mont. 177, 180, 870 P.2d 1351 (1994); Engel v. Gosper, 71 N.J. Super. 573, 579, 177 A.2d 595 (1962). See McDaniel v. Reed, 613 So. 2d 758, 760 (La. App. 1993); but cf. Keele v. Knecht, 621 So. 2d 106 (La. App. 1993) (<HOLDING>). A second category of states looks to the
holding that motion to transfer also must show either that county where action is pending is improper or that venue is mandatory in another county holding that where the murder and robbery occurred in one county but the plan was hatched in another county and the body was subsequently returned to that other county both counties had jurisdiction to try the appellant holding that if a modification petition is filed in a county where venue is appropriate it is improper to transfer the venue to another county merely because venue also would have been proper in the other county however once an enforcement proceeding is undertaken in an appropriate venue venue is improper in a different county over a subsequently filed petition to modify the decree which was the subject of the enforcement proceedings holding that venue was improper in the county of death because no other event occurred there holding that both saline county and grant county had jurisdiction to try the appellant for murder where the actual killing occurred in one county but the acts requisite to the consummation of the murder and the subsequent disposal of the body occurred in the other county