Alexander Woods was convicted of five murders arising from the 2004 killings of four members of a family and their housekeeper. He raised nine claims of ineffective assistance of trial counsel, including claims concerning documents the State allegedly withheld. The Supreme Court of Georgia vacated the trial court’s denial of Woods’s motion for a new trial and remanded for factual findings in the first instance. The trial court must determine whether the State suppressed the documents under Brady or Giglio, whether counsel performed deficiently under Strickland, and whether any deficiency caused prejudice. The Court expressly declined to prejudge the merits of those issues.