Jumar Greer v. State, A17A1451

Jumar Greer was indicted on multiple felony counts and a jury convicted him on six counts.
The trial court entered a written judgment of conviction and imposed written sentences on four counts only.
The trial court did not enter written sentences for the remaining two guilty counts, nor did it enter written notations that those counts merged or were vacated.
Georgia precedent requires a written sentence or a written notation of merger/vacatur for each convicted count before an appeal is ripe.
Because the trial court failed to dispose in writing of all guilty counts, the Court of Appeals held the case was not final and remanded with direction for the trial court to enter written dispositions for all counts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal is ripe when the trial court entered written sentences for some but not all convicted counts	Greer: Appeal should proceed despite missing written sentences because overall judgment was entered	State: Case is not final under Georgia rule unless each convicted count has a written sentence or written notation of merger/vacatur	Court: Appeal is not ripe; remand for trial court to enter written sentences or notations disposing of every convicted count

Keller v. State, 275 Ga. 680 (trial court’s failure to enter a written sentence on each convicted count renders judgment nonfinal)
State v. Riggs, 301 Ga. 63 (trial court must enter either a written sentence or a written notation of merger/vacatur for each count to make judgment final)
Perry v. State, 329 Ga. App. 121 (remanding where written notation of merger was not entered despite oral announcement)
Bass v. State, 284 Ga. App. 331 (remanding where no written sentence or notation was entered for each convicted count)