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entered or apply for a direct or an out-of-time appeal from his conviction and sentence. Although the waiver form provided that Arrington could raise a claim that counsel was ineffective, he indicated on the waiver form that he had been fully advised of his rights and that he was satisfied with his counsel's representation.” “On appeal, Arrington's only discernable argument is that his motion for an out-of-time appeal is not barred by his waiver of post-conviction rights because trial counsel failed to advise him of his right to appeal and the waiver of rights form did not otherwise inform him of the rights he was waiving by pleading guilty.” “[I]t is well-established that a defendant can waive his right to seek post-conviction relief as part of a negotiated plea agreement, so long as the waiver is voluntary, knowing, and intelligent. See Rush v. State, 276 Ga. 541, 542, 579 S.E.2d 726 (2003); Bryan v. State, 296 Ga.App. 341, 342, 674 S.E.2d 390 (2009). … ‘Having received the benefit of the [plea] agreement, [Arrington] cannot now ignore its terms and seek relief via an appeal to this Court.’ Rush, supra, 276 Ga. at 542, 579 S.E.2d 726.” Smith v. Magnuson, 297 Ga. 210, 773 S.E.2d 205 (June 1, 2015). Following pleas to enticing a child and related offenses, habeas court properly found that defendant’s pleas were invalid. Trial court accepted defendant’s pleas as part of a group plea in which defendant incorrectly denied that he “had ever been a patient in a mental health facility or under the care of a psychiatrist. … Plea counsel informed the judge prior to acceptance of Magnuson's pleas that Magnuson had in fact been institutionalized and treated for mental health problems but added that he could not say whether psychiatrists had been involved. Counsel then stated that Magnuson had been found competent to stand trial, to which the court responded, ‘he appears as such.’ The court ultimately accepted Magnuson's pleas without making any further inquiry into his mental health history or his then-current mental state.” At habeas hearing, Magnuson presented expert testimony “that due to the circumstances of the group plea, Magnuson's impulse disorder, and the fact that Magnuson is more susceptible to conformity than the typical person, Magnuson would have answered the plea court's questions in conformity with the general affirmative answer of the group without giving any consideration to or having any real understanding of the consequences of his answers.” Defendant’s therapist also testified that Magnuson “did not understand the severity of the charges being brought against him, and he had no comprehension of how long he might spend in jail, believing that he would spend six or eight weeks in jail and then go home.” Held, record evidence supports habeas court’s finding “that the group dynamic and Magnuson's disorder prevented him from making an intelligent and knowing decision to enter his pleas.” Lejeune v. McLaughlin, 296 Ga. 291, 766 S.E.2d 803 (November 24, 2014). Following guilty plea to murder, habeas court erred by denying relief after hearing at which burden was placed on State to prove voluntariness of plea. Reversing Purvis v. Connell, 227 Ga. 764, 182 S.E.2d 892 (1971) and its progeny, a 4-3 majority rules that on habeas review, the burden is on the petitioner/criminal defendant, not the respondent/State, to prove the involuntariness of a guilty plea. Purvis was based on a misunderstanding of Boykin . “Just a few years before Purvis, the United States Supreme Court held in Boykin that the United States Constitution requires the State to bear the burden of showing on direct review that a plea was voluntary, knowing, and intelligent. See 395 U.S. at 242–244. In Purvis, we extended this allocation of the burden to habeas cases. Relying exclusively on Boykin, we held in Purvis that the United States Constitution forbids Georgia courts to indulge the usual presumption of regularity in a habeas case in which the petitioner contends that his plea was not voluntary, knowing, and intelligent.” Based on “ Parke v. Raley, 506 U.S. 20, 113 S.Ct. 517, 121 L.Ed.2d 391 (1992), making clear in its decision that Boykin did not, in fact, abrogate the presumption of regularity that attaches to final judgments, and nothing about Boykin requires that the State bear the burden of proving the voluntariness of a plea in the context of a collateral attack upon a final judgment.” Remanded for new hearing, although evidence at prior hearings did “not support its finding that Lejeune understood at the time of his plea that, if he instead insisted upon a trial, he could not be compelled to incriminate himself.” Plea colloquy didn’t cover right to remain silent, and trial counsel denied that he ever discussed Lejeune’s right to remain silent. Hines, joined by Benham and Hunstein, dissents. Distinguished, Raheem v. State , 333 Ga.App. 821, 777 S.E.2d 496 (September 16, 2015) (“there is nothing in Lejeune remotely suggesting that the State no longer has the burden of demonstrating, in the context of a direct appeal from a judgment of conviction, that a defendant’s guilty plea was voluntary, knowing, and intelligent.”) Grant v. State, 326 Ga.App. 121, 756 S.E.2d 255 (March 12, 2014). Aggravated assault conviction affirmed, but sentence vacated. Trial counsel rendered ineffective assistance by failing to object to admission of one of defendant’s prior convictions, used to sentence him as a recidivist under OCGA § 17-10-7(c). Record of his 1981 guilty plea to armed robbery showed that defendant was advised of only one of his three Boykin rights. “Grant having produced affirmative evidence showing ‘an infringement of his rights or a procedural irregularity in the taking of the plea,’ the burden should thus shift back to the State to prove the constitutionality of the 1981 plea. Nash [ v. State, 271 Ga. 281, 285, 519 S.E.2d 893 (1999)]. The State has not yet had an opportunity to make such a showing, but we conclude that a reasonable probability exists that, but for trial counsel's deficient performance in failing to object to the use of this plea, Grant might