Marcus Moore was seventeen when he committed two murders and other offenses. After a jury found him guilty, he entered a negotiated agreement under which the State recommended and the court imposed life imprisonment without parole, along with additional consecutive sentences. Moore’s agreement waived appellate and post-conviction review. After the United States Supreme Court held in Roper v. Simmons that the Eighth Amendment bars executing people who were under eighteen when they committed their crimes, Moore moved to correct his life-without-parole sentence as void. The Georgia Supreme Court held that the waiver did not bar a challenge to an illegal sentence. Roper did not itself categorically prohibit life without parole for a juvenile who committed homicide, but its retroactive elimination of the death penalty for juvenile offenders affected Georgia’s 2001 sentencing scheme. At that time, Georgia law permitted life without parole only in a case where the State could legally seek the death penalty. Because Moore’s age made him ineligible for death under Roper, he also could not legally receive life without parole under the statute then in effect. The court reversed the denial of his motion, vacated the life-without-parole sentence, and remanded with direction to impose a lawful sentence. The decision did not disturb the convictions or decide the constitutionality of life without parole for juvenile homicide offenders as a categorical matter.