Jerry Dean Johnson entered a negotiated guilty plea to rape, kidnapping, aggravated assault, and burglary in 2003. In 2021 he filed a trial-court motion for an out-of-time appeal, alleging that plea counsel had failed to advise him about post-conviction procedures. The trial court held an evidentiary hearing and denied the motion on the merits. During Johnson’s appeal, the Supreme Court of Georgia held that a standalone motion for an out-of-time appeal is not a legally cognizable way to obtain relief from constitutional violations allegedly caused by ineffective assistance of counsel. The Court of Appeals of Georgia applied that rule and held that Johnson had no right to pursue the motion in the trial court; any such claim had to be brought through habeas corpus. The appellate court vacated the denial and remanded for entry of the proper dismissal order, without reaching whether Johnson’s plea was knowing and voluntary or whether counsel was ineffective.