Derek Smallwood was convicted of entering an automobile under Georgia law. He argued that the statute was unconstitutionally vague and that the rule of lenity required sentencing under the misdemeanor vehicle-trespass statute instead. The Georgia Supreme Court affirmed. The court held that the entering-an-automobile statute was not vague as applied to Smallwood’s conduct. It also held that the statute was more specific than the vehicle-trespass statute, so the rule of lenity did not apply. The conviction and sentence therefore remained in place.