Coates v. Georgia
Annotate this CaseHubert Coates was convicted of four counts of possession of a firearm by a convicted felon and was sentenced on each count. Coates appealed; the Court of Appeals affirmed his convictions and sentences, concluding that OCGA 16-11-131 (b) (2014)2 permitted a defendant to be separately convicted and sentenced for each of the multiple firearms in his possession. The issue this case presented for the Georgia Supreme Court's review was a question of whether a single course of conduct could result in multiple convictions and sentences under the same statute, the doctrine of substantive double jeopardy was implicated, and the “unit of prosecution,” or the precise act criminalized by the statute, had to be identified. "Reading the statute in a natural and ordinary way, it is clear that the gravamen of the offense is the general receipt, possession, or transportation of firearms by convicted felons, rather than the specific quantity of firearms received, possessed, or transported." Based on this analysis, the Supreme Court concluded the Court of Appeals erred. Accordingly, the decision was reversed, Coates’ convictions and sentences for the four counts of possession of a firearm by a convicted felon vacated, and the case remanded for the trial court to convict and resentence Coates on only one of those counts.
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