Tia Marie Dos Santos entered negotiated guilty pleas to felony murder and related offenses on the first day of her scheduled trial. Eight days later, while still represented by plea counsel and before the end of the term of court, she filed a pro se motion to withdraw the pleas. The trial court later allowed plea counsel to withdraw, appointed post-conviction counsel, held a hearing, and denied the motion on its merits. The Georgia Supreme Court held that the pro se motion was a legal nullity because Dos Santos remained represented when she filed it. Georgia law does not allow a defendant to represent herself while also being represented by counsel, and the plea lawyer’s representation continued through the end of the term unless properly ended. The Court therefore did not decide whether the pleas were coerced or counsel was ineffective. It vacated the order and remanded with direction to dismiss the motion. The Court also emphasized counsel’s continuing duties after a guilty plea and identified habeas corpus or other post-conviction remedies for possible abandonment.