Garry Deyon Johnson was convicted of malice murder and robbery for a 1997 killing and sentenced to life without parole plus 20 years. After lead counsel withdrew, another appointed lawyer remained on the case; a later appointed appellate lawyer never appeared. Johnson filed several pro se post-conviction motions, but years later the trial court allowed and then denied an out-of-time motion for new trial, which Johnson appealed. The Georgia Supreme Court held that a counseled defendant’s pro se filing is not automatically a nullity: although hybrid representation is not a right, courts may recognize timely, procedurally proper pro se filings in their discretion, usually sparingly and with that choice clear on the record. The Court overruled decisions imposing an absolute nullity rule because it lacked a legal basis and could forfeit review when counsel failed to preserve short appeal deadlines. That rule did not revive Johnson’s out-of-time motion, which was no longer cognizable after Cook, or resolve his earlier motions. The Court vacated the orders allowing and denying the out-of-time motion and remanded for its dismissal; the trial court must separately decide whether to recognize and rule on Johnson’s earlier pro se filings.