Humphrey v. GeorgiaAnnotate this Case
In July 1998, Jamel Humphrey negotiated a plea agreement with the State, entered a plea of guilty but mentally ill, was convicted of murder upon his plea, and was sentenced to a term of imprisonment for life with the provision that he would be eligible for parole, but only after he served 25 years of his sentence. Almost sixteen years later, Humphrey filed a motion to vacate his sentence, alleging that the sentence was void because murder was punishable only by death, imprisonment for life without any possibility of parole ever, or imprisonment for life with the possibility of parole at the earliest point permitted by law, which would have been, in Humphrey's case, after fourteen years. The trial court denied his motion, and Humphrey appealed. The Supreme Court reversed: the sentence that the trial court imposed in this case was void to the extent that it purported to limit the power of the Board to parole Humphrey as soon as the statutory law permitted. Accordingly, the Court reversed the denial of the motion to vacate the sentence, and remanded for the trial court to vacate the provision of the sentence limiting Humphrey's eligibility for parole.