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penalty phase closing argument, the district attorney incorrectly stated that a sentence of life imprisonment with the possibility of parole ‘can be only used if there are no aggravating circumstances.’ This argument is improper because a sentence of life imprisonment with parole is always an option for the jury regardless of whether they find the existence of any statutory aggravating circumstances. Perkinson did not object to this argument. Accordingly, a reversal is only required if there is a reasonable probability that the improper argument changed the jury’s exercise of discretion in choosing between life imprisonment, life without parole, and death. See Pace v. State, 271 Ga. 829, 844(32)(h), 524 S.E.2d 490 (1999); Hicks v. State, 256 Ga. 715, 730(23), 352 S.E.2d 762 (1987). Because the trial court correctly and repeatedly charged the jury that life with the possibility of parole was always a sentencing option without regard to the existence of any statutory aggravating circumstances, we conclude that the prosecutor’s misstatement did not reasonably alter the outcome of the penalty phase. See id .” 20. CONTENT – MOTIVE Wright v. State, 319 Ga.App. 723, 738 S.E.2d 310 (February 11, 2013). Armed robbery and related convictions affirmed. Prosecutor’s closing argument, referencing his lack of a job and his desire for victim’s SUV, didn’t “improperly inject his (Wright’) financial circumstances into the state’s closing argument by stating: ‘It's not justice. It's not just to allow that person to sit around with no job to go out on the street and rob people.’ … While motive was not an essential element of any of the charged crimes, the prosecutor was entitled to argue that Wright had a motive, as was developed in evidence; further, the prosecutor was entitled to impugn or condemn such motive. Head v. State, 276 Ga. 131, 135(6), 575 S.E.2d 883 (2003) (‘In making a closing argument, it is counsel's right to impugn or condemn motives.’) (citation and punctuation omitted); Wade v. State, 258 Ga. 324, 326–327(5), 368 S.E.2d 482 (1988) (recognizing that motive for the charged crime was proper subject matter for closing argument); Conner v. State, 251 Ga. 113, 122(6), 303 S.E.2d 266 (1983) (recognizing that counsel may ‘condemn motives, so far as they are developed in evidence’).” 21. CONTENT – PARDON, PAROLE OR CLEMENCY Tollette v. State, 280 Ga. 100, 621 S.E.2d 742 (November 7, 2005). “The likelihood of parole is an improper subject matter for argument by counsel, except for the limited exception allowing counsel to refer to the significance of life without parole and life with eligibility for parole as those meanings are set out in OCGA § 17-10- 31.1(d).” Prosecutor’s argument in defendant’s death-penalty trial that prison “for seven years and re-paroled” was improper, but “entirely harmless … given the fact that the jury had life without parole as an available sentence and was properly charged… that a sentence of life without parole would mean that Tollette would never be eligible for parole unless later adjudicated innocent.” Curles v. State, 276 Ga. 237, 575 S.E.2d 891 (January 27, 2003). Prosecutor’s argument that the judge “can take into consideration [defendants’] good works at church, what they did on their jobs” in sentencing does not violate OCGA § 17- 8-76 because it “makes no specific reference to pardon, parole, or other clemency.” King v. State, 273 Ga. 258, 539 S.E.2d 783 (November 30, 2000). “This Court held in State v. Patillo, 262 Ga. 259, 417 S.E.2d 139 (1992), that a jury should not be informed that a finding of mental retardation bars the imposition of the death penalty. However, the State’s arguments about King’s attempt to place responsibility somewhere else and to avoid the death penalty were directed not at the question of whether a finding of mental retardation would bar the imposition of the death penalty but, rather, toward King’s argument to the jury that his alleged mental retardation suggested he was not capable of committing the crimes of which he was accused. In this particular circumstance, we find that the argument was not improper.” Fletcher dissents. Moore v. State, 242 Ga.App. 249, 529 S.E.2d 381 (February 4, 2000). Armed robbery and firearms convictions affirmed. “Moore contends that his trial counsel was ineffective because he did not object when the prosecutor stated during his closing argument (1) that a witness who testified against Moore might be in danger and (2) that Moore had served only 14 years of a 20-year sentence for his prior armed robbery conviction. We agree with Moore that the prosecutor's closing remarks were highly inappropriate and provided grounds for not only objections from the defense, but also a rebuke from the trial judge. Nevertheless, this case is not in a posture where we are simply reviewing errors by the prosecutor but is before us in the context of an ineffective assistance of counsel claim. As noted above, such a claim requires a showing of both error and prejudice to the defendant.” Possibility of pardon or parole: “Moore's counsel was not deficient in failing to object on the basis of OCGA § 17-8-76, because the prosecutor did not actually argue to the jury that if Moore were convicted, he might not suffer the full penalty imposed by the court. Nevertheless, we note that the prosecutor's statement was, again, highly improper. The fact that Moore had not served all of his prior 20- year sentence was completely immaterial to the issue to be decided by the jury, i.e., whether Moore committed the