Danyel Smith was convicted in 2003 of felony murder in the death of his two-month-old son based on a Shaken Baby Syndrome theory. Years later, Smith filed an extraordinary motion for new trial supported by new expert analysis and modern medical literature contending that the infant's injuries were more consistent with birth trauma, seizures, and other non-abuse explanations than with shaking. After an evidentiary hearing, the trial court denied relief again. The Supreme Court of Georgia vacated that ruling and remanded. It held that the trial court used the wrong framework when assessing materiality: instead of asking how a reasonable jury would likely weigh the new expert evidence against the trial evidence, the court largely decided for itself which experts it believed. Because newly discovered expert opinion must be evaluated through the probable-jury-impact framework established in Georgia new-trial law, the order could not stand.