After a gas-station burglary, police pursued a fleeing Suburban; Kelly was found hiding nearby with cash and wire cutters, and burglary tools were in the vehicle. A jury convicted him of burglary, possessing tools for a crime, and obstruction. On appeal, Kelly challenged his self-representation, standby-counsel limits, comments on his absence, restrictions on evidence and cross-examination, prior-burglary evidence, and the sufficiency of the evidence. The Georgia Court of Appeals held his waiver of counsel was knowing and intelligent and some claims were unpreserved. Assuming error in excluding his academic transcript and admitting the prior burglary, the court found both harmless; it found the evidence sufficient, no cumulative denial of a fair trial, and ineffective-assistance claims procedurally barred for not being raised at the earliest opportunity. It affirmed his convictions and sentence.