Griggs v. State, 304 Ga. 806

Traevis Griggs shot and killed Jewvyn Glover in an apartment on April 21, 2015; Griggs later admitted shooting but claimed self-defense.
After the shooting Griggs purchased gloves and trash bags, returned to the apartment, wrapped/tied the body, fled, and was quickly arrested; physical evidence connected him to the shooting.
A jury convicted Griggs of voluntary manslaughter (as a lesser-included offense of malice murder) and of two counts of felony murder (one predicated on aggravated assault and one on possession of a firearm by a convicted felon), among other offenses.
At sentencing the trial court vacated the voluntary manslaughter verdict and the felony-murder count predicated on aggravated assault, and imposed life without parole for felony murder predicated on unlawful possession of a firearm by a convicted felon.
Griggs appealed, arguing the court should have vacated the felony-murder verdict(s) and sentenced him for voluntary manslaughter instead; the Georgia Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by vacating the voluntary manslaughter verdict and entering judgment/sentence on felony murder predicated on unlawful possession of a firearm	Griggs: Edge and its progeny require that when jury convicts of both voluntary manslaughter and felony murder premised on the same killing, the felony murder conviction should be vacated and voluntary manslaughter enforced	State: Precedent limits Edge’s merger rule; felony murder predicated on unlawful possession of a firearm is independent of the passion/provocation that supports voluntary manslaughter	Court: Affirmed — Edge’s modified-merger rule does not apply to felony murder predicated on possession of a firearm by a convicted felon; trial court did not err

Edge v. State, 261 Ga. 865 (establishes modified merger rule favoring voluntary manslaughter when underlying felony is integral to the killing)
Sanders v. State, 281 Ga. 36 (extends Edge to certain other felonies integral to the homicide)
Anthony v. State, 303 Ga. 399 (discusses scope of felonies susceptible to mitigation by provocation)
DuBose v. State, 299 Ga. 652 (refuses to apply Edge to felony murder predicated on unlawful firearm possession)
Amos v. State, 297 Ga. 892 (reiterates that unlawful firearm-possession-based felony murder is independent of provocation)
Wallace v. State, 294 Ga. 257 (same)
Lawson v. State, 280 Ga. 881 (same)
Sims v. State, 265 Ga. 35 (same)
Clough v. State, 298 Ga. 594 (discusses limits of Edge’s application)
Jackson v. Virginia, 443 U.S. 307 (legal-sufficiency standard review)