Supreme Court of Georgia

Johnson v. State

January 19, 2022313 Ga. 155

Summary

The Supreme Court of Georgia held that the Court of Appeals used the wrong merger analysis when reviewing Johnson's multiple theft-by-taking convictions. Because the convictions involved multiple counts of the same crime, the court was required to determine whether the thefts arose from a single course of conduct and, if so, identify the applicable unit of prosecution. The court vacated the Court of Appeals' merger ruling and remanded for that analysis.