Cody Dowda was convicted of criminal trespass after a jury acquitted him of attempted theft. On appeal from the denial of his motion for new trial, he challenged the sufficiency of the evidence, the admission of hearsay and character evidence, and the trial court’s handling of a jury note that showed confusion about the charges. The Georgia Court of Appeals held that the evidence was sufficient and that any hearsay error was harmless. It nevertheless held that the trial court violated Dowda’s right to counsel by failing to let defense counsel review the jury note and propose an appropriate response. Because the error required reversal but the evidence supported the conviction, the State remained entitled to retry Dowda. The court reversed the criminal-trespass conviction.