Nazario v. State

Summary

The court held that a guilty plea does not waive a claim that convictions merged under Georgia law, because a merged conviction is void and the resulting sentence is illegal. The court nevertheless affirmed most convictions because the limited guilty-plea record did not establish merger, while vacating four of five convictions and sentences for concealing a death because all acts furthered the concealment of one unlawful killing. The court overruled the contrary waiver rule and affirmed in part and vacated in part.