Court of Appeals of the State of Georgia ATLANTA,____________________ October 22, 2025 The Court of Appeals hereby passes the following order: A26A0545. TARIK S. JACKSON v. THE STATE.

In 2001, Tarik Jackson was convicted of eleven offenses, including armed robbery, kidnapping, and possession of a firearm during the commission of a crime, for which Jackson was sentenced as a recidivist to life in prison without the possibility of parole.1 This Court affirmed his convictions on appeal. Jackson v. State, 276 Ga. App. 77 (622 SE2d 423) (2005). In August 2025, Jackson filed a motion to correct void sentence. The trial court dismissed the motion, and Jackson filed this appeal. We lack jurisdiction.

Under OCGA § 17-10-1(f), a court may modify a sentence during the year after its imposition or within 120 days after remittitur following a direct appeal, whichever is later. Frazier v. State, 302 Ga. App. 346, 347–48 (691 SE2d 247) (2010); Burg v. State, 297 Ga. App. 118, 118 (676 SE2d 465) (2009). Once this statutory period expires, as it had here when Jackson filed his void-sentence motion, a trial court may modify a sentence only if it is void. Jones v. State, 278 Ga. 669, 670 (604 SE2d 483) (2004). And a sentence is void only when the trial court imposes punishment that the law does not allow. Jordan v. State, 253 Ga. App. 510, 511 (1) (559 SE2d 528) (2002).

“Motions to vacate a void sentence generally are limited to claims that — even assuming the existence and validity of the conviction for which the sentence was imposed — the law does not authorize that sentence, most typically because it exceeds

Jackson also entered a guilty plea to possession of a firearm by a convicted felon. the most severe punishment for which the applicable penal statute provides.” von Thomas v. State, 293 Ga. 569, 572 (2) (748 SE2d 446) (2013). A direct appeal may lie from an order denying a motion to vacate or correct a void sentence, but only if the defendant raises a colorable claim that the sentence is, in fact, void. Harper v. State, 286 Ga. 216, 217 n. 2 (686 SE2d 786) (2009); Burg v. State, 297 Ga. App. 118, 119 (676 SE2d 465) (2009).

In his void-sentence motion, Jackson claimed that: (1) he was not provided proper notice that three alleged prior felony convictions would be used to enhance his sentence; (2) the State did not prove that he had three prior felony convictions; and (3) at the time of his sentencing Georgia law did not authorize a sentence of life without parole for a non-murder offense. Jackson has previously raised the first two claims in a void-sentence motion, and this Court, on appeal from the denial of those claims, ruled that the claims were not colorable void-sentence claims. Jackson v. State, Case No. A16D0467 (Aug. 2, 2016). Jackson may not relitigate these claims in ths appeal. See Paradise v. State, 321 Ga. App. 371, 373 (740 SE2d 238) (2013) (although a void sentence may be challenged at any time, such a challenge is nevertheless subject to the equally well-established principles of res judicata and the law-of-the-case rule).

Jackson’s third claim is not a colorable void-sentence claim because, at the time of his sentencing, the law provided that “when a three-time recidivist commits a fourth felony for which the maximum penalty is life in prison, the trial court lacks discretion to sentence such felon to anything other than a life sentence without possibility of parole.” State v. Jones, 253 Ga. App. 630, 632 (560 SE2d 112) (2002).

Because Jackson has not raised a colorable void-sentence claim, we lack jurisdiction over this appeal, which is hereby DISMISSED.

Court of Appeals of the State of Georgia Clerk’s Office, Atlanta,____________________ 10/22/2025 I certify that the above is a true extract from the minutes of the Court of Appeals of Georgia.

Witness my signature and the seal of said court hereto affixed the day and year last above written.

, Clerk.