Cecil Mathis pleaded guilty to drug offenses and received a recidivist sentence under OCGA § 17-10-7(c). He later sought to vacate or modify the sentence, relying on § 17-10-7(b.1), which limits recidivist sentencing for specified simple-possession and marijuana-related offenses. The Court of Appeals of Georgia held that the statutory exception applied to Mathis’s convictions and that the trial court had erred in rejecting his motion. The statute had to be construed strictly against the State, and recidivist sentencing was unavailable where the qualifying prior convictions were the specified possession offenses. The court reversed and remanded with direction.