Coates v. State, 304 Ga. 329

Police executed a search in May 2014 and recovered four firearms from Hubert Coates’ residence; less than an ounce of marijuana was also found.
Coates, a convicted felon, was charged with and convicted on four counts of possession of a firearm by a convicted felon (OCGA § 16-11-131(b)).
The Court of Appeals affirmed multiple convictions and sentences, holding the statute permits separate convictions for each firearm.
The Georgia Supreme Court granted certiorari to decide the unit-of-prosecution question under the Double Jeopardy Clause.
The Court interpreted the phrase “any firearm” in OCGA § 16-11-131(b) and concluded the statute criminalizes the general receipt/possession/transportation of firearms by felons, not each individual firearm.
The Court reversed the Court of Appeals, vacated the multiple convictions and sentences, and remanded for conviction and sentencing on a single count.

Issue	Plaintiff's Argument (Coates)	Defendant's Argument (State)	Held
Whether OCGA § 16-11-131(b) allows multiple convictions for simultaneous possession of multiple firearms	Statute criminalizes general possession by a felon; simultaneous possession of multiple firearms yields only one offense	“Any firearm” permits separate convictions/sentences for each firearm possessed	Only one prosecution/conviction permitted for simultaneous possession of multiple firearms under § 16-11-131(b)

State v. Marlowe, 277 Ga. 383 (discusses unit-of-prosecution/substantive double jeopardy analysis)
Sanabria v. United States, 437 U.S. 54 (legislature defines offenses; statutory text controls unit-of-prosecution)
Landers v. State, 250 Ga. 501 (legislative purpose of § 16-11-131 to keep guns from those shown dangerous by prior conduct)
Stovall v. State, 287 Ga. 415 (noting harsher punishment for multiple guns may make sense but requires clear legislative language)
Acey v. Commonwealth, 511 S.E.2d 429 (possession of one or many firearms by a felon constitutes the dangerous act; number of weapons irrelevant)