Bobby Cole was convicted of murder and armed robbery after pleading guilty as a teenager. Decades later, he sought an out-of-time appeal, alleging that ineffective assistance of plea counsel caused the missed deadline. The Georgia Supreme Court vacated the summary denial and remanded. The court held that the trial court had to conduct an evidentiary hearing on whether counsel’s performance deprived Cole of the right to appeal and whether Cole was prejudiced. Because the trial court denied the motion without making the necessary findings, the Supreme Court could not resolve the claim on the existing record. The court left the merits of Cole’s request for the trial court to decide after the hearing.