Andrew W. Bell v. State

CourtCourt of Appeals of Georgia
DecidedJune 3, 2026
DocketA26I0215
StatusPublished

This text of Andrew W. Bell v. State (Andrew W. Bell v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Andrew W. Bell v. State, (Ga. Ct. App. 2026).

Opinion

Court of Appeals of the State of Georgia

ATLANTA,____________________ June 03, 2026

The Court of Appeals hereby passes the following order:

A26I0215. ANDREW W. BELL v. THE STATE.

In this criminal matter, defendant Andrew Bell filed a motion to recuse the trial judge. The motion was assigned to another judge, who denied the motion on May 1, 2025. On June 27, 2025, Bell filed an application with the Supreme Court, which docketed the filing as an interlocutory application that was subsequently transferred to this Court. S25I1323 (Aug. 12, 2025). We, however, lack jurisdiction. Denials of motions to recuse are interlocutory in nature, and appeals of such orders require compliance with the interlocutory appeal provisions of OCGA § 5-6-34. See Ellis v. Stanford, 256 Ga. App. 294, 295(2) (568 SE2d 157) (2002); see also Rolleston v. Glynn County Bd. of Tax Assessors, 213 Ga. App. 552, 553 (445 SE2d 345) (1994). Under OCGA § 5-6-34(b), Bell was required to obtain a certificate of immediate review from the trial court within ten days of the order he sought to appeal. Although Bell filed an application for discretionary appeal, as described in OCGA § 5-6-35, compliance with that procedure does not excuse a party seeking appellate review of an interlocutory order from complying with the additional requirements of OCGA § 5-6-34(b). See Bailey v. Bailey, 266 Ga. 832, 832–33 (471 SE2d 213) (1996). Because Bell failed to comply with the interlocutory appeal procedure by obtaining a certificate of immediate review, we lack jurisdiction to consider this application, which is hereby DISMISSED. In connection with this application, Bell has filed a pro se motion to correct his e-file number. As we lack jurisdiction over the underlying case, the motion is hereby DISMISSED as MOOT.

Court of Appeals of the State of Georgia Clerk’s Office, Atlanta,____________________ 06/03/2026 I certify that the above is a true extract from the minutes of the Court of Appeals of Georgia. Witness my signature and the seal of said court hereto affixed the day and year last above written.

, Clerk.

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Related

Bailey v. Bailey
471 S.E.2d 213 (Supreme Court of Georgia, 1996)
Ellis v. Stanford
568 S.E.2d 157 (Court of Appeals of Georgia, 2002)
Rolleston v. Glynn County Board of Tax Assessors
445 S.E.2d 345 (Court of Appeals of Georgia, 1994)

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Bluebook (online)
Andrew W. Bell v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/andrew-w-bell-v-state-gactapp-2026.