William Nazario pleaded guilty to 17 offenses arising from the killing of his girlfriend and the abuse and restraint of her three young daughters. The trial court sentenced him for all 17 counts, including five convictions for concealing the victim’s death. On direct appeal, Nazario argued that several convictions merged and that the resulting sentences were void. The Georgia Supreme Court rejected the State’s argument that a guilty plea automatically waives merger claims. Under Georgia law, a conviction that merges into another conviction is a nullity, and an illegal sentence imposed on that conviction may be corrected on direct appeal. The court emphasized that a guilty plea limits the factual record, so defendants will rarely prove factual-merger claims, but it does not eliminate review of merger as a legal issue. Here, the indictment and plea record showed that the five concealment convictions arose from one offense and could support only one sentence. The court therefore vacated four concealment convictions and sentences while affirming the remaining convictions and sentences. The decision overruled Georgia appellate cases that had extended guilty-plea waiver doctrine to merger claims.