Andrew W. Bell v. State

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.