Orlando Miller pleaded guilty to failure to register as a sex offender and was sentenced as a recidivist. The State relied in part on a prior nolo contendere plea to establish a predicate felony. The Georgia Court of Appeals held that the nolo contendere plea could not be treated as a prior conviction for recidivist sentencing under Georgia law. Removing that plea left fewer than the required number of qualifying felonies, so the recidivist provisions did not apply. The court vacated the sentence and remanded for resentencing. It did not reach Miller’s separate challenge to the authenticity of other prior-conviction exhibits because that issue could not change the need for resentencing.