State v. Miranda

Summary

The court affirmed the judgment requiring vacatur of the defendant's murder and felony-murder convictions because cumulative homicide convictions arising from the killing of one victim violated double-jeopardy protections. It held that vacatur, rather than merger, applies even when the cumulative convictions are not greater- and lesser-included offenses, because merger creates uncertainty and may expose defendants to collateral consequences. The court also concluded that a vacated conviction may later be reinstated if the controlling conviction is overturned on grounds that do not undermine the vacated conviction.