Carlos E. Valldeparas pleaded guilty to four counts of child molestation and received a forty-year sentence, with twenty years to serve. After the term for withdrawing his plea had expired, he filed a pro se motion asserting that the plea was not knowing or voluntary and that plea counsel had withheld information, misrepresented facts, and applied undue pressure. The trial court treated the filing as an untimely motion to withdraw the plea, although Valldeparas expressly acknowledged that such relief was unavailable and sought sentence modification. The Georgia Court of Appeals held that the court had to look beyond the motion's label and determine whether its substance stated a potential habeas claim based on involuntariness and ineffective assistance. Because the motion could also have been timely as a sentence-modification request, dismissal as untimely was improper. The Court reversed and remanded for consideration on the merits, including whether venue and other requirements for habeas relief were satisfied. It did not reach the separate ineffective-assistance claim because the appellate record was inadequate.