Robert Lee Neal, Sr. v. State

CourtCourt of Appeals of Georgia
DecidedJuly 2, 2026
DocketA26A0215
StatusPublished

This text of Robert Lee Neal, Sr. v. State (Robert Lee Neal, Sr. v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robert Lee Neal, Sr. v. State, (Ga. Ct. App. 2026).

Opinion

FOURTH DIVISION MCFADDEN, P. J., WATKINS and PADGETT, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.gov/rules

July 2, 2026

In the Court of Appeals of Georgia A26A0215. NEAL v. THE STATE.

WATKINS, Judge.

Robert Lee Neal, Sr., fatally shot Dennis Kitchens when Neal pointed and fired

what he purportedly believed to be a non-functioning pellet gun at Kitchens. What

Neal fired at Kitchens was actually a loaded firearm that had been placed by someone

else in the same drawer as the pellet gun. Neal was indicted for numerous crimes, and

a jury found him guilty of involuntary manslaughter,1 aggravated assault,2 and

possession of a firearm during the commission of a felony.3 Following the denial of his

motion for acquittal, Neal appeals his convictions. For the reasons set forth below, we

1 OCGA § 16-5-3(a). 2 OCGA § 16-5-21(a)(2). 3 OCGA § 16-11-106(b)(1). affirm Neal’s convictions, but we remand the case to the trial court for correction of

a scrivener’s error regarding Counts 5 and 6 of the written sentencing order.

On appeal from a criminal conviction, we view the evidence in the light most favorable to the jury’s verdict, with the defendant no longer enjoying a presumption of innocence. We neither weigh the evidence nor determine witness credibility, which are tasks that fall within the exclusive province of the jury, but only determine if the evidence was sufficient for a rational trier of fact to find the defendant guilty of the charged offense beyond a reasonable doubt.4

So viewed, the evidence shows that on May 27, 2021, Neal had several friends

at his house, including Austin Parker and Kitchens. Neal had a non-functioning pellet

gun, which he “always played with,” even pointing it at his friends. On that day,

Parker had brought a firearm to Neal’s house and (as Parker had done on prior

occasions) placed it in the same drawer where Neal kept the pellet gun. Neal reached

in the drawer, grabbed what he claims he thought was the pellet gun, “put it to

[Kitchens’s] stomach[,]” and pulled the trigger. Tragically, Neal had grabbed

Austin’s loaded firearm instead; the gunshot wound ultimately proved fatal.

4 Whitfield v. State, 370 Ga. App. 720, 720–21 (899 SE2d 259) (2024) (citation and punctuation omitted). 2 Neal was indicted on 13 counts, including multiple charges of felony murder

and aggravated assault. A jury found Neal not guilty on several of the counts, and the

trial court merged several others, ultimately sentencing Neal on the three counts that

remained: aggravated assault, involuntary manslaughter as a lesser included charge of

felony murder, and possession of a firearm during the commission of a felony. This

appeal followed.

1. Neal argues that the jury verdict — specifically, finding him guilty of

involuntary manslaughter as a lesser included offense of felony murder, but guilty of

the underlying aggravated assault — is repugnant and must be reversed. We disagree.

“As a general rule, inconsistent verdicts occur when a jury in a criminal case

renders seemingly incompatible verdicts of guilty on one charge and not guilty on

another.”5 Although once viewed as impermissible, inconsistent verdicts are now

allowed to stand because “it is not generally within the court’s power to make

inquiries into the jury’s deliberations, or to speculate about the reasons for any

5 Rutland v. State, 315 Ga. 521, 522(1) (883 SE2d 730) (2023) (citation and punctuation omitted). 3 inconsistency between guilty and not guilty verdicts.”6 “Such verdicts are deemed

constitutionally tolerable because they may reflect an exercise of lenity by the jury that

is not necessarily grounded in its view of the evidence.”7

Repugnant verdicts, on the other hand, require reversal.8 “‘Repugnant

verdicts’ occur when, in order to find the defendant not guilty on one count and guilty

on another, the jury must make affirmative findings shown on the record that cannot

logically or legally exist at the same time.”9 In such a situation, “instead of being left

to speculate about the unknown motivations of the jury regarding its return of

contradictory verdicts, the appellate record makes transparent the jury’s reasoning

why it found the defendant not guilty of one of the charges[.]”10

6 Id. (citation and punctuation omitted). See also Guajardo v. State, 290 Ga. 172, 174(2) (718 SE2d 292) (2011) (“rare” instance where reversal is necessitated under this “narrow” exception). 7 State v. Springer, 297 Ga. 376, 377(1) (774 SE2d 106) (2015). “An example of ‘inconsistent verdicts’ is when a defendant is convicted of possession of a firearm during the commission of the crime of aggravated assault, but found not guilty of aggravated assault.” Rutland, 315 Ga. at 522(1). 8 See Rutland, 315 Ga. at 522(1). 9 Id. (citation and punctuation omitted). 10 McElrath v. State, 308 Ga. 104, 111(2)(c) (839 SE2d 573) (2020) (citation and punctuation omitted). “An example of ‘repugnant verdicts’ is when a defendant is 4 Here, Neal was indicted in Count 2 with felony murder on the basis that “while

in the commission of the offense of aggravated assault, a felony, as alleged in Count

7 of this Indictment, [Neal] did unlawfully cause the death of Dennis Wayne Kitchens,

a human being, by shooting him with a certain firearm[.]” Count 7 charged that Neal

“did unlawfully make an assault upon the person of Dennis Wayne Kitchens, with a

deadly weapon, to wit: a certain firearm by shooting him[.]”

On appeal, Neal argues that the jury could not have found him not guilty of

felony murder for causing Kitchens’s death during the commission of aggravated

assault11 while also finding him guilty of aggravated assault.

The trial court instructed the jury that, as a lesser included offense of Count

2, it could find Neal guilty of involuntary manslaughter for causing Kitchens’s death

without intending to by pointing a gun at him or by committing a reckless act (both

found guilty but mentally ill of felony murder and aggravated assault and not guilty of malice murder by reason of insanity.” Rutland, 315 Ga. at 522(1). In this example, “it is not legally possible for an individual to simultaneously be insane and not insane during a single criminal episode against a single victim, even if the episode gives rise to more than one crime.” McElrath, 308 Ga. at 112(2)(c). 11 See generally Cantrell v. State, 266 Ga. 700, 701 (469 SE2d 660) (1996) (“[W]hen an indictment charges an offense, and the jury returns a verdict of guilty on a lesser included offense, the verdict operates as an acquittal of the greater offense.”). 5 misdemeanors)12 or during the commission of a lawful act in an unlawful manner. The

jury found Neal not guilty of felony murder but guilty of “Involuntary Manslaughter

(Unlawful Act).”

To find Neal guilty of aggravated assault, as charged in Count 7, the jury had

to find that he intentionally attempted to commit a violent injury. And to find him

guilty of “Involuntary Manslaughter (Unlawful Act)” the jury had to find that, while

in the commission of an unlawful act other than a felony, Neal caused Kitchens’s

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Related

Cantrell v. State
469 S.E.2d 660 (Supreme Court of Georgia, 1996)
Guajardo v. State
718 S.E.2d 292 (Supreme Court of Georgia, 2011)
State v. Springer
774 S.E.2d 106 (Supreme Court of Georgia, 2015)
Jones v. State
733 S.E.2d 400 (Court of Appeals of Georgia, 2012)
Russell v. State
848 S.E.2d 404 (Supreme Court of Georgia, 2020)
McELRATH v. State
839 S.E.2d 573 (Supreme Court of Georgia, 2020)
State v. OWENS (And Vice Versa)
862 S.E.2d 125 (Supreme Court of Georgia, 2021)
Rutland v. State
883 S.E.2d 730 (Supreme Court of Georgia, 2023)
Ward v. State
901 S.E.2d 189 (Supreme Court of Georgia, 2024)
Schmitt v. State
901 S.E.2d 102 (Supreme Court of Georgia, 2024)

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Bluebook (online)
Robert Lee Neal, Sr. v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-lee-neal-sr-v-state-gactapp-2026.