David Hill was convicted of felony murder and two aggravated assaults arising from a 2001 shooting. More than a decade later, he filed an extraordinary motion for new trial based on an affidavit from Shaneka Jackson, who claimed to have information supporting an alibi. A successor judge found the affidavit credible, concluded that the State’s investigator had failed to develop the evidence, and granted a new trial. The Supreme Court of Georgia reversed. It held that extraordinary motions based on newly available evidence receive stricter scrutiny than ordinary new-trial motions, and the trial court must apply the governing legal requirements rather than rely on unsupported factual findings. Jackson’s affidavit did not say that she had given the investigator exculpatory information before trial, and its vague account did not establish that Hill could not have participated in the shooting. Hill therefore failed to show that the State possessed or suppressed favorable Brady evidence. He also failed the Timberlake requirements because the information was not newly discovered: Hill knew Jackson was present and had access to her and her prior statement before trial. Even if credited, the proposed testimony was not direct and positive proof of innocence and was unlikely to produce a different result. The Court held that the successor court abused its discretion and reversed the new-trial order.