Undreas Davis was convicted of theft by taking and financial identity fraud and received fifteen consecutive ten-year sentences—150 years without parole—as a recidivist. The trial court counted a federal conviction for possessing stolen mail when imposing the enhanced sentence. Davis argued that the sentence was grossly disproportionate and that the federal conviction did not qualify as a Georgia felony. The Georgia Court of Appeals declined to reach the proportionality claim because Davis had not raised it in the trial court. It nevertheless vacated the sentence because the State failed to prove that the federal offense would be a felony under Georgia law. Federal law criminalized possession of stolen mail without requiring the proof of value or intent that Georgia theft offenses required for felony treatment. The State’s additional evidence about losses and credit-card use was either insufficiently connected to the federal offense or double hearsay from a presentence report. The Court remanded for resentencing without the federal conviction being counted under OCGA § 17-10-7(c). Judge McFadden concurred specially, questioning whether the preservation rule should prevent review of the trial court’s actual sentencing decision.