State v. Springer

The Court overruled Jackson v. State and its progeny in holding that the defendant's convictions for aggravated assault and involuntary manslaughter based on reckless conduct were not mutually exclusive.

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We granted the State’s petition for writ of certiorari to review the Court of Appeals’ decision reversing appellee Roderick Springer’s convictions for aggravated assault and involuntary manslaughter based on reckless conduct on the ground that these verdicts are mutually exclusive. See Springer v. State 328 Ga. App. 654 762 SE2d 433 2014. After reviewing the record and pertinent case law, we hold that under the facts of this case, the jury’s guilty verdicts are not mutually exclusive and reverse the judgment of the Court of Appeals. In doing so, we overrule our decision in Jackson v. State, 276 Ga. 408 577 SE2d 570 2003.

The State presented evidence at trial demonstrating that Springer and a co-defendant exchanged multiple gunshots in a public parking lot, several of which struck the victim, an innocent bystander, causing the victim’s death. Springer was indicted on charges of felony murder, aggravated assault, and possession of a firearm during the commission of a crime. At Springer’s request, in addition to instructing the jury on the offenses set out in the indictment, the trial court also charged the jury on the lesser-included offense of involuntary manslaughter predicated on the misdemeanors of reckless conduct and simple assault. See OCGA § 16-5-3 a involuntary manslaughter unlawful act; OCGA § 16-5-20 simple assault; OCGA § 16-5-60 b reckless conduct. The jury ultimately found Springer guilty of involuntary manslaughter based on reckless conduct, aggravated assault, and possession of a firearm during the commission of a crime. He was sentenced to concurrent terms of 10 and 20 years imprisonment for involuntary manslaughter and aggravated assault, respectively, and a consecutive five-year term of imprisonment on the firearm count.

State v. Springer

The Court overruled Jackson v. State and its progeny in holding that the defendant's convictions for aggravated assault and involuntary manslaughter based on reckless conduct were not mutually exclusive.

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