Carlos Bowser absconded during his jury trial for possession of marijuana with intent to distribute, was convicted in absentia, and later obtained counsel. He then filed a pro se motion seeking to have his appeal rights granted. The Court of Appeals of Georgia held that the motion was a legal nullity because Bowser remained represented by counsel and the attorney had never been authorized to withdraw. The trial court therefore should have dismissed the motion rather than deny it on the merits. The appellate court vacated the denial order and remanded with direction to dismiss Bowser’s motion.