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State, 293 Ga. 569, 573(2) (748 S.E.2d 446) (2013) (‘[A] sentence which is not allowed by law is void, and its illegality may not be waived.’ (Citations, punctuation, and emphasis omitted.)); Nazario v. State, 293 Ga. 480, 487(2)(c) (746 S.E.2d 109) (2013) (‘Void convictions and illegal sentences have never been subject to general waiver rules.’).” 2. Attempt to limit parole violates separation of powers. “ By imposing such a sentence, a court intrudes upon the constitutional prerogative of the State Board of Pardons and Paroles to extend clemency to persons under sentence. See Ga. Const. of 1983, Art. IV, Sec. II, Par. II(a) (‘[T]he State Board of Pardons and Paroles shall be vested with the power of executive clemency, including the powers to grant reprieves, pardons, and paroles....’),” citing “ Terry v. Hamrick, 284 Ga. 24, 25(2) (663 S.E.2d 256) (2008). And whatever the prosecuting attorneys and defendant in a criminal case might agree to, they cannot simply by agreement confer upon the judicial branch an extraconstitutional power to limit the constitutional prerogatives of another branch of the government. See Perez v. State, 254 Ga.App. 872, 873(1) (564 S.E.2d 208) (2002) (‘The authority to grant parole or other relief from the sentence imposed by the trial court rests with the State Board of Pardons & Paroles, not the district attorney's office .’ (Citation omitted.)). To the extent that we held otherwise in Baker v. State, 284 Ga. 280, 281(2) (663 S.E.2d 261) (2008), we overrule that decision.” 3. Suggests, however, that defendant may be held to his bargain. “[Defendant] also promised that he would not seek parole for 25 years. No one should misunderstand our decision as holding that his promise not to seek parole is unenforceable. When a defendant promises the State that he will not ask for parole, his promise is a personal one. It does not require a court to do anything, and it does not purport to limit the constitutional power of the Board. If Humphrey breaks his promise and applies to the Board for parole before he has served 25 years, the State may ask the Board itself or a court to enforce the promise. We express no opinion today about the availability of a remedy for the State, but our decision does not foreclose the possibility of such a remedy.” Simmons v. State, 292 Ga. 265, 736 S.E.2d 402 (January 7, 2013). Felony murder and related convictions affirmed; trial court properly granted State’s motion to withdraw plea agreement. Defendant entered into a plea agreement with the State, receiving a reduced sentence based on her promise to testify truthfully at co-defendant Cooper’s trial about his involvement in the murder. “However, after her plea hearing but before the trial of her co-defendants, Simmons told a cell mate that Cooper was not involved in the murder and did not enter Rucker's home, and instead, stayed in the car. Further, Simmons told another cell mate that she lied during the plea hearing to obtain a lesser sentence. Such statements “defeat[ed] the object of the contract,” which, for the State, was to obtain consistently truthful testimony from Simmons at trial. The State no longer had any way of ensuring that it would obtain such truthful testimony from Simmons after she had already directly contradicted her original story and undermined her own credibility prior to trial. Accordingly, rescission of her agreement with the State was appropriate,” citing Brown (May 5, 2003), below. Rejects defendant’s argument that rescission was premature “because she had not yet given untruthful testimony at the trial of her co-defendants.” Brown v. State, 261 Ga.App. 115, 582 S.E.2d 13 (May 5, 2003). No violation of double jeopardy where defendant violates a plea agreement to testify truthfully at a later proceeding and court therefore sets aside guilty plea, notwithstanding: a) “the plea agreement did not specify that it would be set aside if Brown breached the agreement,” and b) there was no express waiver of double jeopardy. Based on Ricketts v. Adamson , 483 U.S. 1, 107 S.Ct. 2680, 97 L.Ed.2d 1 (1987). Accord, Simmons (January 7, 2013), above. 2. BINDING EFFECT State v. Lewis, 298 Ga. 126, 779 S.E.2d 643 (November 16, 2015). Affirming 330 Ga.App. 412, 767 S.E.2d 771 (2014); trial court’s determination that Lewis didn’t live up to his plea bargain obligation to testify truthfully against his co- defendants vacated and remanded for reconsideration. 1. “[W]e reject the broad proposition posited by [the State and Lewis] that once a trial court accepts a plea agreement in a criminal prosecution, it has no authority to determine whether the parties to that agreement, either the State or the defendant, have complied with its terms and no authority to reject the plea agreement and agreed upon sentence based on one party’s lack of performance if the other party does not complain of the lack of performance.” Court finds from the record of Lewis’s plea “that both the plea agreement and the trial court’s commitment to sentence Lewis according to the terms of that agreement were conditioned upon Lewis’ performance of his promise to provide truthful testimony at the trial of his co-defendants.” 2. Defendant’s right to specific performance of a plea bargain, established in Santobello v. New York, 404 U.S. 257, 261, 92 S.Ct. 495, 30 L.Ed.2d 427 (1971), applies equally to the trial court and to the prosecution. “‘When a trial judge accepts a negotiated plea and the defendant later relied on the terms of the plea agreement to his detriment by waiving certain constitutional rights that cannot be recovered, the failure of the trial judge to adhere to the terms of the negotiated plea would likely offend the integrity and reputation of the criminal justice system even more that any unkept promise made by a prosecutor,’” quoting Court of Appeals at 414 . “Consistent with the principles of fairness recognized

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