Simpson v. State, 310 Ga. App. 63

In 1988, Simpson was convicted by a Fulton County jury of three counts of armed robbery.
Sentence: Count 1 = 20 years; Count 2 = 20 years consecutive to Count 1; Count 3 = 20 years concurrent with Count 2.
In 2009, Simpson filed a motion to set aside void conviction and sentence; trial court denied.
Simpson argued the sentences were unlawfully consecutive and violated double jeopardy.
The issue concerns whether multiple armed robberies in three separate transactions can be punished consecutively.
Georgia law allows consecutive punishment for separate transactions if each sentence is within statutory limits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consecutive sentences for separate armed robberies violate double jeopardy.	Simpson contends the sentences punish the same conduct.	State maintains the offenses were separate transactions not the same conduct.	No error; sentences within statutory range and properly consecutive for separate transactions.

Rooney v. State, 287 Ga. 1, 690 S.E.2d 804 (2010) (no right to concurrent sentences; consecutive allowed within limits)
Booker v. State, 231 Ga. 598, 203 S.E.2d 194 (1974) (same conduct doctrine when separate offenses arise from one act)
Syas v. State, 273 Ga. App. 161, 614 S.E.2d 803 (2005) (separate victims/locations not same conduct)
Summers v. State, 263 Ga. App. 338, 587 S.E.2d 768 (2003) (multiple counts not the same conduct when involving different victims)