In Springer v. State, the Georgia Court of Appeals reversed the defendant’s convictions for involuntary manslaughter and aggravated assault.
The Court held that there was a reasonable probability that the jury returned mutually exclusive verdicts by finding that the defendant acted with criminal intent and criminal negligence at the same time towards the same victim.
The record showed that a fight broke out in the parking lot of a restaurant. Another defendant arrived during the fight, pulled a gun from his pants, and started shooting. There was evidence that Springer was in the crowd and shooting a gun. When police arrived, they found that an innocent bystander had been shot in the back and killed.
Springer was indicted for felony murder, aggravated assault, and possession of a firearm during the commission of a felony. The jury found him guilty of aggravated assault as well as involuntary manslaughter as a lesser-included offense of felony murder. Springer moved for a new trial, the motion was denied, and he appealed, arguing that his convictions should be set aside because the jury returned mutually exclusive verdicts.
According to the Georgia Supreme Court, “verdicts are mutually exclusive where a guilty verdict on one count logically excludes a finding of guilt on the other.” Georgia courts have held verdicts to be mutually exclusive when a jury returns guilty verdicts for both criminal intent and criminal negligence offenses for “the same act by the accused as to the same victim at the same instance of time.” This is because the accused cannot have acted with both criminal intent and criminal negligence in the same act.
The Court of Appeals held that the defendant’s involuntary manslaughter and aggravated assault convictions involved the same act towards the same victim at the same time. In order to determine whether the verdicts were mutually exclusive, the Court looked at the indictment, the evidence, the verdict form, and the jury instructions. The jury’s verdict form found the defendant guilty of involuntary manslaughter based on reckless conduct as a lesser included offense of felony murder. Reckless conduct does not require a finding that the defendant acted with criminal intent, but merely that he acted with criminal negligence. Because of this, the Court held that the involuntary manslaughter conviction was mutually exclusive of the aggravated assault conviction which requires criminal intent.
As a result, the Court of Appeals reversed Springer’s convictions and remanded the case for a new trial.
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