Bass v. Mercer

Given existing precedent, I must concur in the judgment of the majority. However, I write separately to note my concern about the way the “unreasonable delay” element of OCGA § 5-6-48 (c) has been treated over the years. In reaching a decision about whether the delay in filing a transcript is unreasonable, the trial and appellate courts have more often than not focused their inquiry on how many days or months a transcript is tardy. See, e.g., Wagner v. Howell, 257 Ga. 801 (363 SE2d 759) (1988); Fuller v. Mayor &c. of Savannah, 193 Ga. App. 716 (389 SE2d 7) (1989); Burton v. Hamilton, 204 Ga.…