Few v. Blair — Georgia Court of Appeals permits direct appeal of dismissed interlocutory appeal

Case
Tabitha Few v. Richard Blair
Court
Court of Appeals of Georgia
Judge
Tabitha Few (appointment info not available)
Date Decided
August 25, 2026
Docket No.
A27I0014
Topics
Appellate procedure; Interlocutory appeals; Settlement enforcement
Source
Read the full opinion

Background

In this tort action, Tabitha Few sought to enforce a settlement agreement. The trial court denied that motion, and the Court of Appeals granted Few’s application for interlocutory review on December 15, 2025.

Few timely filed her notice of appeal. In July 2026, however, the trial court dismissed the appeal, finding that Few had unreasonably delayed filing a transcript. The trial court certified its dismissal order for immediate review, and Few applied for interlocutory review of that order.

The Court’s Holding

The Court of Appeals granted Few’s application. It held that once a party files a notice of appeal after an interlocutory appeal is granted, the case is in the same procedural posture as a direct appeal from a final judgment.

Because an order dismissing a properly filed direct appeal is itself directly appealable, Few was entitled to appeal the trial court’s dismissal order without first obtaining permission through an interlocutory application. The court gave Few 10 days to file a notice of appeal in the trial court, if she had not already done so.

Key Takeaways

  • A trial court’s dismissal of an appeal following a granted interlocutory appeal is directly appealable.
  • An appellant need not obtain interlocutory permission to challenge that dismissal order.
  • The court granted Few 10 days to file the notice of appeal and directed the trial court clerk to include the order in the appellate record.

Why It Matters

The order clarifies the procedural route for challenging a trial court’s dismissal of an appeal after interlocutory review has been authorized. The dispositive point is the direct appealability of the dismissal order, not the trial court’s certification for immediate review.

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