Markell Rawles was convicted of multiple armed robberies, aggravated assaults, kidnappings, false imprisonments, and firearm offenses. After the State conceded that several appellate issues had arguable merit, Rawles accepted a reduced sentence in exchange for waiving his right to appeal. He later sought habeas relief, and the habeas court treated the appeal waiver as also waiving his right to seek habeas review. The Supreme Court of Georgia reversed and remanded. A waiver of direct appeal does not automatically establish a separate waiver of the constitutional right to petition for habeas corpus. The State bore the burden of proving that Rawles knowingly and voluntarily waived the particular right at issue, and the trial-court colloquy showed at most an appeal waiver. The Court concluded that the record did not support the habeas court’s finding that Rawles had waived habeas review. A dissent would have vacated and remanded for the habeas court to apply the correct standard in the first instance, rather than reversing outright.