Phu Sy Ngo pleaded guilty to burglary and, during the same term of court, filed a motion to withdraw the plea. He expressly asked the trial court to appoint counsel to assist with that motion, but the court denied the request and then denied the motion to withdraw. The Georgia Court of Appeals held that the Sixth Amendment right to counsel attaches when a defendant seeks to withdraw a guilty plea during the term in which the conviction was entered. The trial court therefore had to appoint counsel or obtain a constitutionally valid waiver before deciding the motion. The court also rejected the State’s harmless-error argument because Ngo alleged that his plea was not entered knowingly and voluntarily, making the absence of counsel presumptively prejudicial under controlling Georgia precedent. The court reversed and remanded for a new hearing on the motion to withdraw, to be conducted with appointed counsel or a valid waiver of counsel.