Willie Frank Wright represented himself at trial and was convicted of aggravated assault and family-violence battery. During the unusually long period before the trial court ruled on his amended motion for new trial, Wright obtained counsel and asked the court to appoint or recognize counsel for the remaining proceedings. He argued that the court failed to address that request and also should have instructed the jury on insanity. The Court of Appeals of Georgia held that the trial court erred by failing to rule on Wright’s request for counsel while substantial portions of the post-trial process remained. That error required reversal of the convictions. The court did not decide whether an insanity instruction was warranted because the record contained no evidence supporting it, and the issue could be reconsidered if a retrial produced an evidentiary basis.