The Sleeping Giants: Two Georgia Statutes That Could Unlock Post-Conviction Justice

“No Way Out” — Article 1 of 10 | A GPS Investigative Series on Post-Conviction Justice in Georgia

On March 4, 2026, Chief Justice Nels Peterson of the Georgia Supreme Court did something extraordinary. In a concurring opinion joined by seven of the court’s nine justices, he admitted what anyone trapped inside Georgia’s criminal justice system already knew: the post-conviction system is broken. Peterson called it “a mess” — created “in large part because of a series of well-meaning but shortsighted decisions this Court made over the course of several decades.” He acknowledged that “no rational person would have chosen the system we have today” and called directly on the Georgia General Assembly to fix what the courts had broken. ¹

Peterson’s admission was historic. But it only described one piece of the trap — the tangled procedural rules governing ineffective-assistance-of-counsel claims. The full picture is far worse. And the solution may already be written into Georgia law.

Two existing Georgia statutes — one dating to 1863, the other containing the most powerful safety-valve language in Georgia’s habeas corpus framework — already provide the tools to reshape post-conviction justice in Georgia. They are not obscure footnotes. They are pillars of the Georgia Code, carried forward through every revision for over a century. The legislature wrote them. Georgia courts refused to enforce them. And right now, as the 2026 legislative session enters its final weeks, the General Assembly has the power — and the obligation — to demand that its own laws be followed.

This is not about creating new rights. This is about enforcing the ones that already exist.

The First Giant: The Miscarriage of Justice Exception

Buried within Georgia’s habeas corpus statute lies a single sentence with the power to unlock post-conviction relief for every wrongfully convicted person in the state. The full text of O.C.G.A. § 9-14-48(d) sets up a general rule: if a habeas petitioner failed to follow procedural rules at trial or on appeal, relief “shall not be granted” unless the petitioner shows “cause” for noncompliance and “actual prejudice.” That is the procedural default rule — the wall that blocks most habeas claims. ²

But then comes the exception — and its language is extraordinary:

“In all cases habeas corpus relief shall be granted to avoid a miscarriage of justice.”

Not “may be granted.” Not “in some cases.” Not “in exceptional circumstances.” The legislature wrote SHALL be granted. In ALL cases. This is the safety valve — a direct command from the people’s elected representatives that no procedural barrier, no missed deadline, no lawyer’s error can stand in the way of relief when the alternative is unjust imprisonment.

The plain reading of this statute is unmistakable: when a person’s imprisonment constitutes a miscarriage of justice, courts must grant relief. Period.

How Georgia Courts Killed the Exception

Despite the mandatory language, Georgia courts have spent four decades rewriting this exception into near-irrelevance. The systematic narrowing began with Valenzuela v. Newsome in 1985, when the Georgia Supreme Court acknowledged the exception but immediately began restricting it. The court stated that the term “miscarriage of justice” is “by no means to be deemed synonymous with procedural irregularity, or even with reversible error” — so far, a reasonable interpretation. But then the court went further, declaring the term “demands a much greater substance, approaching perhaps the imprisonment of one who, not only is not guilty of the specific offense, but who is in no way even culpable.” ³

That final phrase — “in no way even culpable” — rewrote the statute. Under this interpretation, a person wrongfully convicted of murder who happened to have committed a minor, unrelated offense might not qualify. The court effectively added a moral purity test that appears nowhere in the statutory text. The legislature wrote “miscarriage of justice.” The court rewrote it to mean “actual innocence plus moral perfection.”

In Walker v. Penn (1999), the court tightened the vise further, calling the exception “an extremely high standard” that “is very narrowly applied” — and reversed a habeas trial court that had granted relief under the exception. ⁴

In State v. Colack (2001), the court went further still, holding that the miscarriage of justice concept is “only a basis for excusing the defendant’s procedural default, and is not an independent ground for granting habeas relief.” ⁵

And in Gavin v. Vasquez (1991), the court reversed yet another habeas court that had granted relief to avoid a miscarriage of justice, finding the jury instruction error was “harmless beyond a reasonable doubt.” ⁶

The Pattern: Trial Courts Try to Do Justice. The Supreme Court Stops Them.

What emerges from the case law is a pattern that should alarm every Georgian. When habeas trial courts — the judges closest to the facts, who have reviewed the evidence and heard testimony — invoke the miscarriage of justice exception and grant relief, the Georgia Supreme Court reverses them. The statute says “shall be granted.” The court system says “shall almost never be granted.”

This is not statutory interpretation. It is judicial nullification of a legislative directive. The General Assembly told courts to grant relief in all cases where imprisonment constitutes a miscarriage of justice. The courts rewrote that command into a standard so high that virtually no one can meet it.

The Human Cost: Aaron Keith Penn

Aaron Keith Penn was convicted of malice murder in 1988 for the shooting death of Michael Atkins. Penn’s defense was justification — self-defense. A witness, Horace Ragland, provided an affidavit stating he had seen the shooting and observed the victim’s brother remove a pistol from the victim after the shooting but before police arrived. The trial court denied a motion for new trial, calling the evidence “merely cumulative.” ⁴

Penn filed a habeas corpus petition. After evidentiary hearings, the habeas court found that with the corroborating testimony, “the jury would likely have believed that the victim had a gun and that [Penn] had no reasonable choice but to shoot the victim in defense of self.” The habeas court granted relief under the miscarriage of justice exception.

The Georgia Supreme Court reversed — establishing the “extremely high standard” language that has blocked habeas petitioners ever since.

Penn was eventually paroled in 2001 after serving approximately 13 years. But the legal standard set in his case — Walker v. Penn — is the wall that blocks everyone who comes after him. Every time a habeas trial court considers invoking the miscarriage of justice exception, Walker v. Penn is the case that tells them they cannot. One man’s case became the precedent that traps thousands.

The Second Giant: Georgia’s 160-Year-Old Void Judgment Statute

The second sleeping giant is even older. O.C.G.A. § 17-9-4 declares:

“The judgment of a court having no jurisdiction of the person or subject matter, or void for any other cause, is a mere nullity and may be so held in any court when it becomes material to the interest of the parties to consider it.”

This statute has been part of Georgia law since the Original Code of 1863, § 3513 — before the Fourteenth Amendment, before the modern habeas corpus framework, before any living Georgian was born. The legislature has carried it forward through every code revision for over 160 years: Code 1868 § 3536, Code 1873 § 3594, Civil Code 1895 § 5369, Civil Code 1910 § 5964, Code 1933 § 110-709. It has never been repealed, amended, or narrowed. ⁷

The phrase “void for any other cause” is sweeping. It extends beyond jurisdictional defects. It contains no time limitation. A void judgment “may be so held in any court when it becomes material to the interest of the parties to consider it.” If a conviction was obtained through a documented constitutional violation — suppressed exculpatory evidence, a coerced confession, racial discrimination in jury selection, prosecution under an unconstitutional statute — the plain language of this statute treats that conviction as a “mere nullity.” And the logic is inescapable: the Constitution of the United States is the supreme law of the land. It supersedes every statute, every procedural rule, and every court order in every state. No conviction obtained in violation of the people’s Constitution can be allowed to stand — because a judgment born of a constitutional violation was never legitimate to begin with. It is void not by technicality, but by the foundational principle that no government action taken in defiance of the Constitution carries the force of law.

Chester Got It Right. Harper Took It Away.

In 2008, the Georgia Supreme Court correctly interpreted this statute. In Chester v. State, a 4-3 decision, the court held that the word “judgment” in § 17-9-4 means what it says — and that a conviction is as much a “judgment” as a sentence. If void sentences can be challenged at any time (as prior precedent held), void convictions must also be challengeable at any time. The door opened. ⁸

One year later, the door slammed shut.

Chief Justice Leah Ward Sears, who voted with the Chester majority, resigned from the court in 2009. Her replacement, Justice David Nahmias, joined with the three Chester dissenters to form a new 4-3 majority. In Harper v. State, this new majority overruled Chester, holding that “a motion to vacate a conviction is not an appropriate remedy in a criminal case” and calling Chester “an improvident departure from more than a century of precedent.” ⁹

Justice Melton, writing for the three dissenters, argued that Chester had correctly “eliminated the unnecessary distinction between a ‘sentence’ and a ‘conviction’ for purposes of allowing a challenge to a void ‘judgment.'” The dissent’s point was textual: the statute says “judgment.” A judgment encompasses both conviction and sentence. The legislature made no distinction. The court invented one.

Same statute. Same words. Same Constitution. Different result — because one person on the bench changed.

Richard James Harper, the man whose case was used to close this door, was convicted of murder in DeKalb County in 1982. He served approximately 40 years before being paroled. His motion to vacate was denied on the merits — the trial court had jurisdiction. But the Supreme Court used his appeal to close the door for everyone else.

The Timeline of Elimination

When viewed together, the pattern is not just concerning — it is systematic:

• 1985: Valenzuela v. Newsome narrows the “miscarriage of justice” exception to near-impossibility
• 1999: Walker v. Penn establishes “extremely high standard” — reverses habeas court that granted relief
• 2001: State v. Colack holds miscarriage of justice is not an independent ground for relief
• 2004: Legislature imposes four-year habeas corpus deadline (§ 9-14-42) — the first in Georgia history
• 2008: Chester v. State correctly interprets § 17-9-4 to apply to void convictions (4-3)
• 2009: Harper v. State overrules Chester after single justice replacement (4-3)
• 2022: Cook v. State eliminates out-of-time appeals overnight, dismissing all pending cases
• 2023: H.B. 126 (codifying out-of-time appeals) passes both chambers with overwhelming bipartisan support — 172-1 in the House, 46-7 in the Senate — and dies because the Senate substitute arrived at 12:15 a.m. on sine die
• 2025: Governor Kemp signs H.B. 176, codifying out-of-time appeals and granting Cook defendants a grace period through June 30, 2026 — a significant but partial correction that leaves the deeper structural failures documented in this article unaddressed
• 2026: Chief Justice Peterson declares the system is “a mess” and calls on the legislature to fix it

Each decision closed another door. Each closure pushed defendants further into the habeas corpus system. But habeas corpus itself has been constrained by the four-year deadline, the narrowed miscarriage of justice exception, the denial of counsel, and the practical barriers to legal access documented in GPS’s previous reporting. ¹⁰

Cadedra Lynn Cook — 20 years old when she pled guilty to felony murder in 2013 — became the vehicle for the most dramatic closure. Her case, Cook v. State, eliminated out-of-time appeals entirely. Every pending appeal in Georgia was dismissed overnight. Cook is now 32 years old, currently serving a life sentence at McRae Women’s Facility. The Georgia Law Review called it “a true procedural tragedy.” ¹¹

Enforcement, Not Creation: The Legislative Argument That Changes Everything

The conventional political argument for post-conviction reform runs into a wall: opponents frame it as being “soft on crime.” Creating new rights for convicted people is politically toxic.

But these two statutes change the argument entirely. The legislature does not need to create new rights. It needs to enforce the ones it already has.

The framing is simple, honest, and constitutionally grounded:

• Georgia law already says that habeas relief SHALL be granted to avoid a miscarriage of justice. We are asking you to enforce your own law.
• Georgia law already says that a void judgment is a mere nullity. We are asking you to enforce your own law.
• The Georgia Supreme Court — not the legislature — narrowed these statutes beyond recognition. We are asking you to restore them to their plain meaning.

This is not a liberal or conservative position. It is a rule-of-law position. The legislature wrote these words. The courts ignored them. The legislature has the power — and the constitutional obligation — to correct that.

What the Legislature Must Do: The Restorative Override

There is a well-established mechanism for exactly this situation. Legal scholars call it a “restorative override” — when a legislature amends a statute to explicitly reject a court’s narrowing interpretation and restore the original meaning.

The most powerful precedent is the Civil Rights Act of 1991, in which Congress overrode as many as twelve Supreme Court decisions that had narrowed workplace anti-discrimination protections. Congress wrote directly into the statute’s findings that “certain aspects of recent decisions and opinions of the Supreme Court have unduly narrowed or cast doubt upon the broad application” of the law, and that “legislative action is necessary to restore the prior consistent and long-standing executive branch interpretation.” The Voting Rights Act Amendments of 1982 and the Civil Rights Restoration Act of 1988 followed the same model — legislatures explicitly rejecting court interpretations and restoring the statutes to their intended meaning.

Chief Justice Peterson has effectively invited the Georgia General Assembly to do exactly this. When the Chief Justice of Georgia’s highest court says “the system is broken” and “we did a lot of the breaking” and the legislature must act — that is a judicial invitation to override. It is the strongest possible signal that the courts will accept legislative correction.

The Georgia Post-Conviction Justice Act — GPS’s proposed reform package — should include these specific restorative overrides:

First: Define “miscarriage of justice” by statute — and ground it in constitutional supremacy. The Georgia General Assembly should amend O.C.G.A. § 9-14-48(d) to include a statutory definition that begins with the most fundamental principle in American law: any conviction obtained through a violation of the United States Constitution or the Georgia Constitution is, by definition, a miscarriage of justice. The Constitution is the highest law of the land — the law of the people themselves. It is supreme over every statute, every court rule, and every procedural deadline in every state. No conviction obtained in violation of that charter can be permitted to stand, because a government that secures a conviction by breaking its own Constitution has exceeded the very authority that empowers it to prosecute. The statutory definition should therefore encompass any documented constitutional violation — including but not limited to Brady violations, prosecutorial misconduct, coerced confessions, racial discrimination in jury selection, and denial of the right to counsel — as well as actual innocence supported by new evidence, convictions based on since-discredited forensic science, convictions where the defendant received constitutionally deficient representation that affected the outcome, and convictions resulting from coerced guilty pleas.

Second: Clarify that the miscarriage of justice exception overrides all procedural bars — including the four-year habeas deadline in O.C.G.A. § 9-14-42. The current judicial interpretation treats the exception as merely excusing procedural default within § 9-14-48(d). If the legislature intends this to be a true safety valve, it must say so explicitly.

Third: Amend O.C.G.A. § 17-9-4 to specify that “void for any cause” includes documented constitutional violations — and that judgments void under this section may be challenged by motion in the trial court at any time. The principle here is fundamental and admits no exception: the Constitution of the United States is the highest law in our system of government. It is the law of the people — ratified by the people, supreme over every statute, every court rule, and every government action. When the state obtains a conviction by violating the Constitution — whether through suppressing evidence, coercing a confession, discriminating in jury selection, or denying the right to counsel — that conviction was never lawfully obtained. It is void not because of a technicality, but because the government exceeded its authority under the very charter that grants it the power to prosecute in the first place. No procedural deadline, no judicial narrowing, and no interest in “finality” can cure a conviction that the Constitution forbids.

Fourth: Reverse Harper v. State by statute. Codify the Chester v. State interpretation that § 17-9-4 applies equally to void convictions and void sentences. The legislature’s own word — “judgment” — has never distinguished between the two. The court’s distinction was invented, not enacted.

Fifth: Build on the progress of H.B. 176. In May 2025, Governor Kemp signed House Bill 176, which codified out-of-time appeals and included a grace period for defendants affected by Cook v. State to refile before June 30, 2026. This was a significant step — proof that the legislature can act when it chooses to. But H.B. 176 addressed only one piece of the broken system. The dormant statutes documented in this article — § 9-14-48(d) and § 17-9-4 — remain judicially neutralized. The legislature must now apply the same willingness it showed with H.B. 176 to the deeper structural reforms these statutes demand. ¹²

A Message to the Georgia General Assembly

This article will be delivered to every member of the Georgia General Assembly through the GPS Postal System. The message is direct:

Chief Justice Peterson told you the system is broken. He told you the courts broke it. He asked you to fix it. What he described — the tangled IAC process — is only one example of the mess. The dormant statutes documented in this article are another. The courts have gone counter to the very laws as they were written. The words “shall be granted” and “void for any cause” were your predecessors’ words — the Georgia General Assembly’s words — and the courts have refused to honor them.

You do not need to wait for the 2027 session to begin acting. Even after Crossover Day, the General Assembly retains the power to pass a resolution expressing legislative intent — a statement of findings that the judicial narrowing of O.C.G.A. § 9-14-48(d) and O.C.G.A. § 17-9-4 has exceeded legislative intent. A resolution is non-binding, but it creates legislative history. When the statutory amendments come in 2027, courts will look to that resolution as evidence of what the legislature meant.

You can authorize a study committee or interim committee to examine post-conviction reform during the off-session — creating hearings, testimony, and official findings that build the foundation for 2027 legislation.

And you can begin drafting the Georgia Post-Conviction Justice Act now — actual bill text in General Assembly format, ready for sponsors to file the moment the 2027 session opens.

The tools are in your hands. They were written by legislators who came before you. They have been on the books for decades — one of them for over 160 years. The courts silenced them. Only you can wake them up.

This is the first article in a 10-part investigative series, “No Way Out,” building the public case for the Georgia Post-Conviction Justice Act targeting the 2027 legislative session. Each article will document another door that was sealed, who sealed it, who is trapped behind it, and how to reopen it. The series plan is available at gps.press/vision2027/no_way_out.

We are not asking Georgia to create new rights. We are asking Georgia to enforce the rights it already has.

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Call to Action: What You Can Do

Awareness without action changes nothing. Here’s how you can help push for accountability and real reform:

Join the GPS Advocacy Network — Sign up at https://gps.press/become-an-advocate/ and we’ll advocate on your behalf every week. GPS identifies your state legislators, crafts personalized letters on the most pressing prison issues, and sends them directly to the representatives who represent you. You receive a copy of every letter. It takes two minutes to sign up — we handle the rest.

Tell My Story — Are you or a loved one affected by Georgia’s prison system? GPS publishes first-person accounts from incarcerated people and their families. Submit your story at https://gps.press/category/tellmystory/ and help the world understand what’s really happening behind the walls.

Contact Your Representatives — Your state legislators control GDC’s budget, oversight, and the laws that created these failures. Find your Georgia legislators at https://gps.press/find-your-legislator/ or call Governor Kemp at (404) 656-1776 or the GDC Commissioner at (478) 992-5246.

Demand Media Coverage — Contact newsrooms at the AJC, local TV stations, and national criminal justice outlets. More coverage means more pressure.

Amplify on Social Media — Share this article and tag @GovKemp, @GDC_Georgia, and your local representatives. Use #GAPrisons, #PrisonReform, #GeorgiaPrisonerSpeak.

File Public Records Requests — Georgia’s Open Records Act gives every citizen the right to request incident reports, death records, staffing data, medical logs, and financial documents at https://georgiadcor.govqa.us/WEBAPP/_rs/SupportHome.aspx.

Attend Public Meetings — The Georgia Board of Corrections and legislative committees hold public meetings. Your presence is noticed.

Contact the Department of Justice — File civil rights complaints at https://civilrights.justice.gov. Federal oversight has forced abusive systems to change before.

Support Organizations Doing This Work — Donate to or volunteer with Georgia-based prison reform groups fighting for change on the ground.

Vote — Research candidates’ positions on criminal justice. Primary elections often determine outcomes in Georgia.

Contact GPS — If you have information about conditions inside Georgia’s prisons, reach us securely at GPS.press.

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Further Reading

Blackstone Is Dead: Georgia Abandoned American Justice

The foundational GPS investigation documenting how Georgia systematically dismantled every safeguard Blackstone’s principle was meant to protect — from the IAC trap to the four-year habeas deadline.

The Death of Habeas Corpus Is Killing Innocent People

GPS’s deep investigation into how Georgia’s unprecedented four-year habeas corpus deadline traps innocent people in prison when the average DNA exoneration takes 14 years.

A Constitutional Betrayal: Georgia’s Deadline on Freedom

The constitutional case against Georgia’s habeas corpus time bar, tracing 830 years of habeas tradition and the 2004 law that broke it.

A New Path to Justice: What Georgia’s HB 176 Means for Incarcerated Individuals

How the 2025 law codifying out-of-time appeals partially addressed the Cook v. State fallout — and the June 30, 2026 deadline for those affected.

Every Door Locked: Innocent People Trapped in Georgia Prisons

GPS’s comprehensive investigation into the scope and scale of wrongful conviction in Georgia — an estimated 2,500 innocent people in a system with no mechanism to find them.

Guilty Until Proven Innocent: You WILL Be Found Guilty

An in-depth investigation into how Georgia’s criminal justice system functions to guarantee convictions — from plea coercion to inadequate defense counsel.

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Research Explainers

GPS Research Explainers distill complex data and legal research into accessible briefings. These explainers are directly relevant to the issues covered in this article:

Research Explainers for Advocates

Data-driven briefings designed for advocates working on Georgia prison reform — including post-conviction legal barriers, wrongful conviction statistics, and conviction integrity gaps.

Research Explainers for Families

Accessible research summaries for families of incarcerated Georgians navigating the post-conviction system — habeas corpus deadlines, legal access barriers, and available resources.

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Explore the Data

GPS makes GDC statistics accessible to the public through several resources:

• GPS Statistics Portal — Interactive dashboards translating complex GDC reports into accessible formats, updated within days of official releases.
• GPS Lighthouse AI — Ask questions about Georgia’s prison system and get answers drawn from GPS’s investigative archive and data analysis.
• Machine-Readable Pages for Researchers — GPS maintains AI-optimized pages for data analysis:
  • AI Content Index — https://gps.press/ai-index/

The AI Content Index has links to numerous machine readable pages, but this is all that is needed by an AI to fully understand all the data. You can learn more about using GPS Data with AI in are article on the topic:

How to Use GPS Data with AI Tools (https://gps.press/how-to-use-gps-data-with-ai-tools/)

A step-by-step guide showing researchers, advocates, families, and journalists how to use GPS’s machine-readable data pages with AI tools like ChatGPT, Claude, and Gemini to analyze Georgia prison conditions, statistics, and policy.

Contact GPS at media@gps.press for access to underlying datasets used in this analysis.

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About Georgia Prisoners’ Speak (GPS)

Georgia Prisoners’ Speak (GPS) is a nonprofit investigative newsroom built in partnership with incarcerated reporters, families, advocates, and data analysts. Operating independently from the Georgia Department of Corrections, GPS documents the truth the state refuses to acknowledge: extreme violence, fatal medical neglect, gang-controlled dorms, collapsed staffing, fraudulent reporting practices, and unconstitutional conditions across Georgia’s prisons.

Through confidential reporting channels, secure communication, evidence verification, public-records requests, legislative research, and professional investigative standards, GPS provides the transparency the system lacks. Our mission is to expose abuses, protect incarcerated people, support families, and push Georgia toward meaningful reform based on human rights, evidence, and public accountability.

Every article is part of a larger fight — to end the silence, reveal the truth, and demand justice.

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Footnotes

1. WSB-TV, Georgia’s Top Judge Says ‘System is Broken’, https://www.wsbtv.com/news/local/atlanta/georgias-top-judge-says-system-is-broken-needs-lawmakers-help-fix-it/NDH3ZTUGQFH23IO6L2W4FZU2DQ/ [↩]
2. O.C.G.A. § 9-14-48(d), Georgia Habeas Corpus Statute, https://law.justia.com/codes/georgia/title-9/chapter-14/article-2/section-9-14-48/ [↩]
3. Valenzuela v. Newsome, 253 Ga. 793, 325 S.E.2d 370 (1985), https://law.justia.com/cases/georgia/supreme-court/1991/s91a0933-1.html [↩]
4. Walker v. Penn, 271 Ga. 609, 523 S.E.2d 325 (1999), https://law.justia.com/cases/georgia/supreme-court/1999/s99a0930-1.html [↩][↩]
5. State v. Colack, 273 Ga. 361, 541 S.E.2d 374 (2001), https://www.courtlistener.com/opinion/1379248/state-v-colack/ [↩]
6. Gavin v. Vasquez, 261 Ga. 568, 407 S.E.2d 756 (1991), https://law.justia.com/cases/georgia/supreme-court/1991/s91a0933-1.html [↩]
7. O.C.G.A. § 17-9-4, Georgia Void Judgment Statute, https://law.justia.com/codes/georgia/title-17/chapter-9/article-1/section-17-9-4/ [↩]
8. Chester v. State, 284 Ga. 162, 664 S.E.2d 220 (2008), https://case-law.vlex.com/vid/chester-v-state-no-894628535 [↩]
9. Harper v. State, 286 Ga. 216, 686 S.E.2d 786 (2009), https://case-law.vlex.com/vid/harper-v-state-no-894351396 [↩]
10. GPS, Blackstone Is Dead: Georgia Abandoned American Justice, https://gps.press/blackstone-is-dead-georgia-abandoned-american-justice/ [↩]
11. Paxton Murphy, The Procedural Tragedy of Cook v. State, Georgia Law Review Vol. 58:439 (2023), https://georgialawreview.org/wp-content/uploads/2025/01/Paxton-Murphy-The-Procedural-Tragedy-Of-Cook-v.-State-A-Call-to-the-General-Assembly-to-Finish-What-It-Started-58-Georgia-Law-Review-439-2023.pdf [↩]
12. GPS, A New Path to Justice: What Georgia’s HB 176 Means for Incarcerated Individuals, https://gps.press/a-new-path-to-justice-hb-176/ [↩]