Supreme Court of Georgia

Adams v. State

July 1, 2025

Summary

The Supreme Court of Georgia affirmed Xavier Adams, Jr.’s convictions, holding that the modified merger rule does not apply to felony murder predicated on felon‑in‑possession, that the voluntary manslaughter and felony‑murder verdicts are not mutually exclusive, and that the trial court did not commit plain error in its comments, jury instructions, or response to a jury note, the latter claim being waived.