Background
Michael Stanley Few pleaded guilty on December 8, 2025, to trafficking methamphetamine, possession of methamphetamine with intent to distribute, fleeing or attempting to elude law enforcement, possession and use of drug-related objects, and improper display of a license plate. He received a sentence of 25 years’ confinement followed by five years’ probation.
Few filed a notice of appeal from his conviction on January 15, 2026. He also moved to withdraw his guilty plea; the trial court denied that motion on January 16, 2026. Few filed an amended notice of appeal on March 12, 2026.
The Court’s Holding
The Court of Appeals dismissed the appeal for lack of jurisdiction. Because Georgia law now requires an application for discretionary review to initiate an appeal directly from a guilty plea, Few could not proceed through a direct appeal from his conviction.
The court also held that the appeal was untimely. Few filed his original notice 38 days after the final disposition, beyond the 30-day deadline. And although denial of a motion to withdraw a guilty plea is directly appealable, his amended notice challenging that January 16 order was filed more than 30 days later.
Key Takeaways
- A direct appeal from a guilty plea must be initiated through Georgia’s discretionary-review procedure.
- Failure to use the required discretionary-appeal process deprives the appellate court of jurisdiction.
- A notice of appeal, including an amended notice appealing denial of plea withdrawal, must be filed within 30 days of the appealable order.
Why It Matters
The order underscores that appellate procedure can be dispositive in criminal cases. Defendants seeking review after a guilty plea must select the correct appellate vehicle and comply with the jurisdictional filing deadline.