Johnson v. State

315 Ga. 876

FINAL COPY S22A0964. JOHNSON v. THE STATE. PINSON, Justice. Over the past two decades, this Court has applied an absolute rule that anything filed by a criminal defendant on his or her own while still represented by counsel is a “legal nullity.” In this case, we asked the parties and amici whether that rule is correct. In other words, is a pro se filing made by a defendant who is actually or presumptively represented by counsel always a nullity? For the reasons set out below, we now answer that question in the negative. Although a defendant does not have a constitutional or…