Derek Burns, who was convicted of aggravated assault and other crimes, argued that the State violated his Sixth Amendment right to counsel by listening to recorded jail calls between him and his lawyer. After an earlier remand, the trial court held an evidentiary hearing and reviewed the calls in camera before denying Burns’s motion for new trial. The Supreme Court of Georgia affirmed. It held that the particular communications were not protected by the attorney-client privilege on the record presented, so their disclosure did not violate the Sixth Amendment right to counsel. The Court expressly did not decide whether the calls were confidential because the privilege issue resolved the appeal. A separate concurrence addressed and corrected part of the Court of Appeals’ reasoning, while two justices dissented.