Jackson v. GeorgiaAnnotate this Case
In 2004, appellant Prentiss Jackson entered a negotiated guilty plea to one count of statutory rape, registered with the sexual offender registry, and listed an address in Houston County. He was made aware of the requirement to update his registration information within 72 hours prior to any change of address. Nevertheless, in 2011, he moved to Bibb County without registering his new address within the required period of time. He was indicted, and the caption of the one-count indictment read: “Failure to register as a sex offender.” Jackson was ultimately convicted by jury and sentenced to 30 years, serving six in prison with the remainder on probation. Jackson appealed, arguing primarily that the indictment against him was insufficient. The Court of Appeals found no error and affirmed the conviction. The Georgia Supreme Court disagreed that the indictment was sufficient to withstand a general demurrer, and was deficient and void. Consequently, Jackson’s conviction was reversed.