Supreme Court of Georgia

Early v. State

May 3, 2022313 Ga. 667

Summary

The court affirmed the convictions and sentences, holding that the trial court properly admitted a brief jail video containing the appellant's statement that he was a murderer and properly declined to merge the aggravated-assault conviction. The video was admissible because its probative value was not substantially outweighed by unfair prejudice, and the unpreserved constitutional challenge did not establish plain error. The aggravated-assault count could not merge into the vacated voluntary-manslaughter verdict or into the felony-murder count predicated on unlawful firearm possession.