Owens v. State

Summary

The Supreme Court of Georgia affirmed Norris Owens’s conviction for felony murder predicated on possession of a firearm by a first‑offender probationer, rejecting his argument that the felony‑murder count should have been merged into a voluntary manslaughter verdict. The Court applied the “modified merger rule” from Edge v. State and held that the rule does not extend to firearm‑possession felony murder, thereby finding no error in the trial court’s sentencing.