And because the motion for new trial is pending, any notice of appeal to an appellate court "has not yet ripened, and the trial court retains jurisdiction to dispose of the motion for new trial." State v. Hood , 295 Ga. 664, 664, 763 S.E.2d 487 (2014). As a result, so long as a "case properly remains within the jurisdiction of the trial court," and absent an applicable exception such as an interlocutory appeal as provided in OCGA § 5-6-34 (b), any appeal must be dismissed.

Oladunni's motion in arrest of judgment "was pending when [he] filed [his] notice[s] of appeal, and as far as we know, his motion still is pending today." State v. Hood, 295 Ga. 664 (763 SE2d 487) (2014). Because Oladunni's motion in arrest of judgment remains pending, we lack jurisdiction over his appeals.

(a) First, Brooks argues that the trial court erred by not ordering an evidentiary hearing in response to Brooks's motion seeking leave to supplement his motion for new trial because, until a notice of appeal was filed, the trial court still had jurisdiction to allow amendments to the motion for new trial, despite its prior denial of the motion. Although Brooks is correct that the trial court retained jurisdiction over the case at that time, see State v. Hood , 295 Ga. 664, 664, 763 S.E.2d 487 (2014), the trial court's continuing jurisdiction does not answer whether Brooks was entitled to supplement his motion for new trial at that time. We conclude that he was not.

Oladunni's motion in arrest of judgment "was pending when [he] filed [his] notice[s] of appeal, and as far as we know, his motion still is pending today." State v. Hood , 295 Ga. 664, 763 S.E.2d 487 (2014). Because Oladunni's motion in arrest of judgment remains pending, we lack jurisdiction over his appeals.

[7] (c) Finally, Appellant’s first notice of appeal ripened upon the entry of the nolle pros order that made the judgment final, so it is not legally relevant that he did not file a second notice of appeal within 30 days after its entry. See State v. Hood, 295 Ga. 664, 664-665, 763 S.E.2d 487 (2014) (stating that a notice of appeal filed after final judgment, but before an order disposing of a motion for new trial, will ripen upon a trial court’s denial of the motion for new trial). See also Spears v. State, 367 Ga. App. 92, 94-97, 883 S.E.2d 866 (2023) (holding that a notice of appeal, which was timely filed after the denial of the motion for new trial, ripened after the trial court issued a nolle pros order, even though the appellate court had dismissed the original appeal because of the existence of pending counts).

On the same day, trial counsel filed a motion to modify sentence, but the record does not show that the trial court ever ruled on that motion. On April 17, 2015, trial counsel also filed a notice of appeal on Kelly's behalf, but that premature notice of appeal could not have ripened until the motion for new trial was no longer pending, see Pounds v. State , 309 Ga. 376, 382, 846 S.E.2d 48 (2020) ("[B]ecause the motion for new trial is pending, any notice of appeal to an appellate court ‘has not yet ripened, and the trial court retains jurisdiction to dispose of the motion for new trial.’ ") (quoting State v. Hood , 295 Ga. 664, 664, 763 S.E.2d 487 (2014) ), and the order granting a new trial, as discussed below, was favorable to Kelly and so could not have provided a basis for him to appeal, see Bivens v. Todd , 222 Ga. 84, 85, 148 S.E.2d 424 (1966) (after enactment of Appellate Procedure Act of 1965, as before, a party's appeal had to be dismissed when "the only judgment from which he could appeal [was] completely favorable to him"). On October 19, 2021, at a hearing on the motion for new trial (and nearly six months after the trial court had directed the Attorney General to appoint conflict counsel within 30 days), the assistant district attorney explained that the Attorney General had not been able to find a prosecutor to volunteer to take this case and had not yet appointed conflict counsel for the State.

. See also State v. Hood, 295 Ga. 664, 664-665 (763 S.E.2d 48 (2014) (where motion for new trial was pending when State filed its notice of appeal, jurisdiction remained with the trial court and the appeal was dismissed).

"The concept of a notice of appeal ripening is well established in the context of appeals from criminal convictions and motions for new trial." Bowman , 358 Ga. App. at 614 (1), 856 S.E.2d 11 ; see, e.g., Berrien v. State , 300 Ga. 489, 491 (1) n.2, 796 S.E.2d 718 (2017) ("[A] notice of appeal that is untimely from the final judgment may become a premature notice of appeal that ripens when an order dismissing a motion for new trial is entered."); State v. Hood , 295 Ga. 664, 664-665, 763 S.E.2d 487 (2014) (a notice of appeal filed while a motion for new trial is pending ripens upon denial of the motion); McCulley v. State , 273 Ga. 40, 43 (4) n.3, 537 S.E.2d 340 (2000) (a notice of appeal filed after the oral pronouncement of a sentence ripens upon the entry of the written sentence).