Estuardo Canales was convicted after a jury trial of rape, incest, and statutory rape arising from the sexual abuse of his teenage stepdaughter. The trial court imposed life without parole for rape, plus consecutive prison terms for the other convictions. On appeal, Canales argued that the sentence was unauthorized because the jury could have based a rape conviction on conduct predating the repeal of the governing sentencing statute. The Court of Appeals of Georgia rejected his specific guilty-plea notice argument because he was convicted at trial, not by a plea. It nevertheless held that the record did not show the statutory aggravating finding required for a life-without-parole sentence under the pre-2009 sentencing scheme, and that the jury instructions left open the possibility of a pre-2009 offense. The court vacated the rape sentence and remanded for resentencing.