David Britt entered an Alford plea to failing to register as a sex offender and later sought to withdraw the plea. The trial court allowed him to proceed without counsel at the plea-withdrawal hearing but did not advise him of the dangers of self-representation. The Court of Appeals of Georgia reversed and remanded. It held that the record did not establish a valid waiver of counsel or a clear waiver of appellate counsel, and directed a new hearing conducted in conformity with the constitutional requirements.