Hyde v. State, 299 Ga. 135

In 1999 Hyde committed murders; in 2000 a jury convicted him of malice murder and related offenses.
The trial court, applying OCGA § 17-10-7(c), sentenced Hyde as a recidivist to life without parole for malice murder.
The felony murder verdict was later vacated and remaining counts were merged for sentencing purposes.
Hyde’s 2002 direct appeal affirmed his convictions.
In May 2014 Hyde filed a pro se motion arguing his life-without-parole sentence was void because the law did not authorize recidivist life-without-parole for murder at the time of sentencing.
The trial court denied the motion; the State conceded error on appeal and the Supreme Court of Georgia reversed and remanded for a legal sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hyde’s life-without-parole sentence is void because the statute did not authorize recidivist punishment for capital felonies in 2000	Hyde: sentence is void because OCGA § 17-10-7(c) did not apply to capital felonies (murder) in 2000	State: trial court denied motion (but conceded error on appeal)	Court: sentence void; reversal and remand for lawful sentence

Humphrey v. State, 297 Ga. 349 (2015) (a punishment not authorized by law is void)
Rooney v. State, 287 Ga. 1 (2010) (void-sentence claim may be raised anytime by motion to vacate)
Funderburk v. State, 276 Ga. 554 (2003) (life-without-parole imposed in 2000 for malice murder was void because § 17-10-7(c) did not apply to capital felonies at that time)
Hyde v. State, 275 Ga. 693 (2002) (direct appeal affirming convictions)
Grimes v. State, 293 Ga. 559 (2013) (noting later legislative amendment removing the capital-felony exception from § 17-10-7(c))