Stribling v. State, 304 Ga. 250

Victim William Glenn Thomas, Jr. suffered a severe beating at his office, sustaining at least 15 blows, 38 injuries including a fractured skull and massive brain trauma; he was hospitalized, placed in a medically induced coma and on a ventilator, and later died after life support was withdrawn.
Autopsy listed cause of death as multiple blunt force injuries. Medical testimony acknowledged theoretical possibility of survival with continued life support but described survival as unlikely given the extent of injuries and victim's age.
Bobby Rex Stribling, Jr. was identified after Thomas’s truck and belongings were used/sold; police found Thomas’s items in Stribling’s motel room and Stribling confessed to striking Thomas, taking cash, wallet, keys, and fleeing in the truck.
A Wayne County grand jury indicted Stribling for malice murder, aggravated battery, aggravated assault with intent to rob, armed robbery, burglary, and theft by taking; a jury convicted him on all counts.
Stribling appealed, arguing insufficiency of the evidence because withdrawal of life support was an independent, intervening cause of death; he conceded his assault caused the hospitalization and life support placement.
The Georgia Supreme Court affirmed the murder conviction (finding proximate-cause satisfied) but sua sponte vacated sentences for counts that should have merged with others (aggravated battery and aggravated assault with intent to rob).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency/proximate cause of death	State: Stribling’s beating caused injuries that proximately caused death; withdrawal of life support was foreseeable and not an independent intervening cause.	Stribling: Life-support withdrawal was the intervening and ultimate cause; medical testimony showed theoretical survival possibility.	Court: Evidence sufficient—jury could reasonably find Stribling’s attack proximately caused death; theoretical survival was speculative and could be rejected.
Merger of convictions/sentencing	State: (not contested below) multiple convictions and sentences imposed.	Stribling: (did not raise on appeal) but court may correct merger errors.	Court: Vacated sentences for aggravated battery (merged with malice murder) and aggravated assault with intent to rob (merged with armed robbery).

State v. Jackson, 287 Ga. 646 (proximate-cause standard for criminal causation)
Wilson v. State, 190 Ga. 824 (injury as proximate cause when it constitutes sole, direct, or accelerating cause)
Franklin v. State, 295 Ga. 204 (foreseeability of subsequent events arising from original injury; intervening cause analysis)
Robinson v. State, 298 Ga. 455 (proximate cause is a jury question)
Shields v. State, 285 Ga. 372 (jury may reject speculative or theoretical possibilities)
Singley v. State, 198 Ga. 212 (wound as proximate cause even if death results from subsequent pneumonia)
Sullivan v. State, 301 Ga. 37 (merger principles for overlapping convictions)
Atkinson v. State, 301 Ga. 518 (vacatur of merged counts on appeal without remand)
Douglas v. State, 303 Ga. 178 (aggravated assault with intent to rob merges with armed robbery)