Public-domain · open source
OpenJurist

241 Ga. 596

247 S.E.2d 92

Stephens v. Hopper

Supreme Court of Georgia

Decided July 6, 1978

Supreme Court of Georgia · decided 1978-07-06

Relies on State v. Estevez · Potts v. State

Good law ✅— No negative treatment on recordhow we know

Decided 1978-07-06

How this case has been cited

Cited by 111 later decisions (8 by the Supreme Court) — most recently March 2021 · most notably Zant v. Stephens (1983), Drinkard v. Walker (2006)

23 federal appellate · 68 state decisions

600197819801990200020102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

Undercofler, Presiding Justice,

¶1concurring specially.

¶2I believe Division 1 of the majority opinion can be stated more concisely as follows:

¶31. Separate prosecutions for crimes arising from the same criminal transaction are barred generally. They are not barred where the court lacks jurisdiction or the court orders separate trials in the interest of justice. Code Ann. § 26-506 (b) (c).

¶42. Separate punishment (conviction) of a crime is barred where it is included as a matter of law in another crime for which the defendant has been convicted. Crimes are included as a matter of law by statute or judicial decisions.

¶53. Separate punishment (conviction) of a crime is barred when it was included as a matter of fact in proving another crime for which the defendant has been convicted.

¶6(a) When the elements of the separate crimes have been proved by additional and distinct facts, the crimes are not included as a matter of fact and the defendant may be convicted of both crimes. In such case, the proof may overlap in part, but the proof of either crime does not encompass the other. Potts v. State, 241 Ga. 67 (243 SE2d *605510) (1978).

¶7(b) When all, or less than all, the facts which were necessary to prove one crime are the only facts which proved the other crime the latter crime is included as a matter of fact and the conviction of the latter crime is barred. In such case, the proof of the included crime is encompassed by the proof of the other crime. State v. Estevez, 232 Ga. 316 (206 SE2d 475) (1974).

¶84. Allen, Burke, Zilinmon, Williams and Pryor are not inconsistent withPoiis. The hypothetical case in Pryor should be disregarded.

/241/ga/596 · .json · Public domain