Thomas Houston sought an out-of-time appeal from convictions entered after guilty pleas to two murders and other crimes arising from a series of home invasions. He argued that the trial court misled him by saying that appeals were unavailable after a guilty plea and that his plea counsel was ineffective. The Supreme Court of Georgia held that the trial court’s statement was erroneous, but an out-of-time appeal is available only for issues that can be resolved from the existing plea and sentencing record. Houston’s ineffective-assistance and coercion claims required factual development and therefore had to be pursued, if at all, through habeas corpus rather than a belated direct appeal. Because the record did not establish a qualifying ground for an out-of-time appeal, the court affirmed the denial of Houston’s motion.