Eddie Clark pleaded guilty to felony murder and related offenses and later sought an out-of-time appeal. The trial court summarily denied the request without a hearing. The Georgia Supreme Court vacated the order and remanded. The court held that when a defendant alleges that ineffective assistance of plea counsel caused the failure to file a timely appeal, the trial court must hold an evidentiary hearing to determine whether counsel was deficient and whether the defendant was prejudiced. The trial court could not resolve that claim summarily on the existing record. The Supreme Court did not decide whether Clark was entitled to an out-of-time appeal and directed the trial court to conduct the required hearing.