Supreme Court of Georgia

Edvalson v. State

September 28, 2020310 Ga. 7

Summary

The Supreme Court of Georgia held that OCGA §16-12-100(b)(5) permits only a single prosecution and conviction for the simultaneous possession of multiple visual media depicting child sexual abuse, reversing the Court of Appeals and remanding for vacating the eleven convictions. The Court based its decision on a plain‑meaning construction of the word “any” and applied the rule of lenity, concluding that multiple images constitute one act for double‑jeopardy purposes.