Supreme Court of Georgia

Johnson v. State

January 19, 2022313 Ga. 155

Summary

The court vacated the Court of Appeals’ ruling on whether Johnson’s multiple theft-by-taking convictions merged and remanded for application of the proper merger analysis. It held that the Court of Appeals improperly used the actual-evidence test and failed to analyze whether the thefts arose from a single course of conduct under the applicable unit-of-prosecution framework. No separate opinions were filed.