Boyd v. Washington

In 2008, Steven Wayne Boyd was convicted of armed robbery and robbery by force. He was sentenced to life for armed robbery and 20 years concurrent for robbery by force. The Court of Appeals affirmed. Boyd v. State, 302 Ga. App. 455 691 SE2d 325 2010. He filed a habeas petition in 2010, alleging, among other things, that the trial court erred in sentencing him as a recidivist. Specifically, Boyd claimed that the trial court sentenced him as a recidivist to life without the possibility of parole after inappropriately considering two of his guilty pleas from 2004 in connection with two other prior felony convictions to enhance his sentence. See OCGA § 17-10-7 a and c. The habeas court denied relief, concluding that Boyd had not actually been sentenced as a recidivist, and this Court granted Boyd’s application for a certificate of probable cause to determine whether the habeas court erred in reaching that conclusion. For the reasons that follow, we affirm.