Rebekah Yohman pleaded guilty to felony fleeing and attempting to elude, along with related offenses. The State appealed her sentence, arguing that Georgia’s recidivist-punishment statute required the maximum sentence because Yohman had a prior felony conviction. The trial court concluded that the statute did not apply because Yohman had served only part of the prior sentence in a county jail rather than a penal institution. The Court of Appeals vacated the sentence and remanded for resentencing. Reading the fleeing statute and recidivist statute together, the court held that a prior felony conviction can trigger recidivist treatment when the defendant was sentenced to confinement in a penal institution. The governing definition includes a place of confinement for people accused or convicted of violating state law, and the statute does not require the prior sentence to consist entirely of confinement. The court also explained that the fleeing statute independently barred suspension, probation, deferral, withholding, merger, and concurrent service of the sentence. The trial court therefore applied the wrong legal standard.