Denny v. State

The majority concludes in Division 1 that because Denny’s actions involved three officers, there were “three separate victims” and the evidence was sufficient to convict Denny of three separate counts of misdemeanor obstruction of an officer. Because I believe that the number of officers is not determinative of the number of offenses committed, I respectfully dissent.

It is clear that OCGA §§ 16-1-6 and 16-1-7, relied on by the majority, do not always permit the State to charge a defendant with multiple counts of an offense merely because the facts show he committed a single act affecting more…