Erik Smith pleaded guilty to child-related offenses and later sought an out-of-time appeal, alleging that plea counsel’s ineffective assistance frustrated his right to appellate review. The Court of Appeals of Georgia vacated the trial court’s denial of relief and remanded. It held that the trial court applied the wrong legal analysis when it treated Smith’s dissatisfaction with his sentence as insufficient to establish deficient performance. The trial court was directed to reconsider the claim under the governing ineffective-assistance framework.