Richard Ringold appealed from the denial of a motion to withdraw his guilty plea, after receiving an out-of-time appeal in a case that had previously reached the Georgia Supreme Court. The State argued that the court could not reach the merits because Ringold filed the motion while represented by counsel. The Georgia Supreme Court agreed with the State. It held that Ringold’s pro se motion was a legal nullity because a represented defendant may not independently pursue that motion in the trial court. The trial court therefore should have dismissed the filing rather than decide its merits. The Supreme Court vacated the trial court’s order and remanded with direction to dismiss the pro se motion. The court did not decide the potential merits of Ringold’s claims concerning plea counsel or post-conviction counsel.