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Trial court erred by sentencing defendant as a recidivist for possession of a firearm by a convicted felon; as the Court of Appeals correctly ruled in “ King v. State, 169 Ga.App. 444, 313 S.E.2d 144 (1984), OCGA § 17–10–7(a), which requires courts to sentence defendants with a prior felony conviction to the maximum time authorized for any subsequent conviction, does not apply to violations of OCGA § 16–11–131,” relating to possession of a firearm by convicted felon. Such as reading would make meaningless the provision of OCGA § 16-11-131 which provides for a sentencing range of 1-5 years. Overrules other decisions, however, which interpreted King to mean that prior convictions can’t be used to support both recidivist sentencing (on offenses for which felon status isn’t an element of the offense) and felon status (on offenses for which felon status is an element of the offense). Accord, Morris v. State , 297 Ga. 426, 774 S.E.2d 665 (June 29, 2015). Wynn v. State, 332 Ga.App. 429, 773 S.E.2d 393 (June 8, 2015). Armed robbery and related convictions affirmed; trial court properly sentenced defendant to life without parole for armed robbery under OCGA § 17-10-7(c). Murray v. State, 328 Ga.App. 192, 761 S.E.2d 590 (July 10, 2014). Burglary conviction affirmed; trial court erred by failing to allow defendant to challenge validity of prior convictions, but not reversible as defendant failed to carry burden of showing any invalidity at motion for new trial hearing. “Consequently, even though the trial court clearly erred at the sentencing hearing by telling Murray that he could not challenge the voluntariness of his guilty pleas at that hearing, such error is not reversible since Murray has not pointed to any affirmative evidence showing an irregularity with any of the pleas.” Cody v. State, 324 Ga.App. 815, 752 S.E.2d 36 (November 19, 2013). Child molestation and related convictions affirmed; trial court properly sentenced defendant as a recidivist. “Although conceding that he had been convicted of prior felony offenses, Cody argues that he had not been ‘sentenced to confinement in a penal institution’ as contemplated by OCGA § 17–10–7(a), citing that his prior sentences were either wholly or in part suspended or probated. This argument has already been rejected. See, e.g., Cook v. State, 305 Ga.App. 516, 518(2), 699 S.E.2d 831 (2010); Johnson v. State, 272 Ga.App. 294, 295(3), 612 S.E.2d 29 (2005); Bennett v. State, 132 Ga.App. 397, 398–399(3), 208 S.E.2d 181 (1974). ‘Since [Cody] was sentenced to ... confinement in a penal institution with the privilege of serving it on probation, his sentence was in compliance with OCGA § 17–10–7(a). Cook, supra.” Mack v. State, 323 Ga.App. 821, 748 S.E.2d 299 (September 6, 2013). Following guilty plea to armed robbery, trial court properly denied motion to modify recidivist life sentence. Contrary to defendant, OCGA § 17–10–7(a), which provides that repeat offenders be sentenced to the ‘the longest period of time prescribed for the punishment of the subsequent offense,’ and the armed robbery statute, OCGA § 16–8–41(b), which provides for a punishment of ‘imprisonment for life or by imprisonment for not less than ten nor more than 20 years,’” are not “vague and ambiguous.” “Mack contends that it is not possible to determine whether ‘the longest period of time’ means life, or 20 years.” Court of Appeals disagrees: “the construction of OCGA § 17–10–7(a) as applied to the armed robbery statute is clear: ‘[t]he longest period of time prescribed for punishment of armed robbery is life imprisonment.’ (Citations omitted.) Lester v. State, 309 Ga.App. 1, 5(2), 710 S.E.2d 161 (2011); see also Singleton v. State, 293 Ga.App. 755, 757(2), 667 S.E.2d 711 (2008) (same).” Barber v. State, 316 Ga.App. 701, 730 S.E.2d 176 (July 9, 2012). Convictions for rape and related offenses affirmed, but sentence vacated and remanded: defendant wasn’t subject to sentencing pursuant to OCGA § 17-10-7(c) where defendant wasn’t convicted of one of three felonies used to support the sentence at the time he committed the offenses on trial. “The terms of OCGA § 17–10–7(c) are clear and unambiguous, and they plainly forbid parole only when a defendant, ‘after having been convicted’ of three felonies, ‘commits [another] felony.’ [fn] See Dobbs v. State, 180 Ga.App. 714, 715–716(2) (350 S.E.2d 469) (1986). [fn] Accordingly, the record fails to show a basis for applying the sentencing provisions of OCGA § 17–10–7(c) in this case.” State here only showed two felonies for which defendant had been convicted at the time of commission of the offenses on trial; the third charge was pending at the time the offense on trial was committed, becoming a conviction later. Smith v. State, 312 Ga.App. 174, 718 S.E.2d 43 (October 20, 2011). Rape, kidnapping, and related convictions affirmed; based on six prior felonies, trial court properly sentenced defendant to two consecutive sentences of life without parole pursuant to OCGA § 17-10-7(a) and (c). Jefferson v. State, 309 Ga.App. 861, 711 S.E.2d 412 (June 13, 2011). In entering defendant’s recidivist sentence for possession of marijuana with intent to distribute, trial court properly exercised its discretion to require the entire sentence

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