2021 Georgia Code
Title 50 - State Government
Chapter 21 - Waiver of Sovereign Immunity as to Actions Ex Contractu; State Tort Claims
Article 2 - State Tort Claims
§ 50-21-25. Immunity of State Officers or Employees for Acts Within Scope of Official Duties or Employment; Officer or Employee Not Named in Action Against State; Settlement or Judgment

Universal Citation: GA Code § 50-21-25 (2021)
  1. This article constitutes the exclusive remedy for any tort committed by a state officer or employee.A state officer or employee who commits a tort while acting within the scope of his or her official duties or employment is not subject to lawsuit or liability therefor.However, nothing in this article shall be construed to give a state officer or employee immunity from suit and liability if it is proved that the officer's or employee's conduct was not within the scope of his or her official duties or employment.
  2. A person bringing an action against the state under the provisions of this article must name as a party defendant only the state government entity for which the state officer or employee was acting and shall not name the state officer or employee individually.In the event that the state officer or employee is individually named for an act or omission for which the state is liable under this article, the state government entity for which the state officer or employee was acting must be substituted as the party defendant.
  3. A settlement or judgment in an action or a settlement of a claim under this article constitutes a complete bar to any further action by the claimant against a state officer or employee or the state by reason of the same occurrence.

(Code 1981, §50-21-25, enacted by Ga. L. 1992, p. 1883, § 1.)

Law reviews.

- For note, "Finding Immunity: Manders v. Lee and the Erosion of 1983 Liability," see 55 Mercer L. Rev. 1505 (2004).

JUDICIAL DECISIONS

O.C.G.A. § 50-21-25(a) is not unconstitutional on the grounds that the statute exceeds the scope of the voter approved constitutional ballot amendment which authorized the Tort Claims Act, O.C.G.A. § 50-21-20 et seq. Riddle v. Ashe, 269 Ga. 65, 495 S.E.2d 287 (1998).

O.C.G.A. § 50-21-25(a) does not violate equal protection by creating a class of citizens who are denied the right to seek recovery from persons who injure them. Riddle v. Ashe, 269 Ga. 65, 495 S.E.2d 287 (1998).

Construction with O.C.G.A. § 36-92-3. - Due to the nearly identical language between O.C.G.A. §§ 36-92-3 and50-21-25, the General Assembly intended to provide immunity for municipal employees in the context of torts involving a covered motor vehicle, which is comparable to the immunity granted to state employees in the context of all torts, as long as the pertinent conditions have been satisfied; thus, by the passage of O.C.G.A. § 36-92-3, the legislature intended to foreclose all recovery against municipal employees for torts committed within the scope of employment and involving the use of a covered motor vehicle. DeLoach v. Elliott, 289 Ga. 319, 710 S.E.2d 763 (2011).

Medicaid status irrelevant to constitutionality.

- Grant of official immunity from a malpractice suit to a state-employed doctor based on the patient's status as a Medicaid patient did not violate the constitutional rights of the patient's parents as the due process and equal protection clauses of the U.S. and Georgia Constitutions protected only rights, and a waiver of sovereign immunity under the Georgia Tort Claims Act, O.C.G.A. § 50-21-20 et seq., was merely a privilege. Porter v. Guill, 298 Ga. App. 782, 681 S.E.2d 230 (2009).

Only government entities protected by Act.

- In an action on a note brought by the Georgia Higher Education Assistance Corporation, the defendant's tort counterclaim was not barred by the Tort Claims Act, O.C.G.A. § 50-21-20 et seq., since a corporation cannot be a "state officer or employee," and the plaintiff was not one of the state government entities referred to in O.C.G.A. § 50-21-25. Garrett v. Georgia Higher Educ. Assistance Corp., 217 Ga. App. 415, 457 S.E.2d 677 (1995).

Abusive foster parents not state actors under 42 U.S.C.

§ 1983. - District court erred in holding the defendants were state actors for purposes of 42 U.S.C. § 1983 under the lexus/joint access test because as private parties plaintiffs' conduct as allegedly abusive foster parents was not "symbiotic" with that of the state and the state's role did not amount to that of a "joint participant" with the plaintiffs in the context of child abuse. Rayburn v. Hogue, 241 F.3d 1341 (11th Cir. 2001).

Foster parents immune from liability.

- In a wrongful death action by the child's biological parents, the foster parents were entitled to sovereign immunity because they were state officers or employees under the Tort Claims Act, O.C.G.A. § 50-21-20 et seq., and the Georgia Department of Human Services was the proper party defendant in the biological parents' action under the Tort Claims Act. Dep't of Human Servs. v. Duncan, 351 Ga. App. 332, 831 S.E.2d 4 (2019), cert. denied, No. S19C1564, 2020 Ga. LEXIS 194 (Ga. 2020).

Limited immunity.

- Tort Claims Act, O.C.G.A. § 50-21-20 et seq., provides limited, rather than blanket, immunity from suit. Riddle v. Ashe, 269 Ga. 65, 495 S.E.2d 287 (1998).

Employees entitled to official immunity.

- Merely styling a suit against a public officer as one brought against the officer personally does not deprive the officer of any immunity to which the officer might otherwise be entitled under the Tort Claims Act, O.C.G.A. § 50-21-20 et seq. Coultas v. Dunbar, 220 Ga. App. 54, 467 S.E.2d 373 (1996); Brooks v. Barry, 223 Ga. App. 648, 478 S.E.2d 616 (1996), cert. denied, 522 U.S. 899, 118 S. Ct. 246, 139 L. Ed. 2d 176 (1997).

Plaintiff could not sidestep the notice requirements of the Georgia Tort Claims Act (GTCA) by alleging that the plaintiff was suing the defendants as individuals acting outside of the scope of the defendants' official duties and employment as the GTCA was the exclusive remedy for any tort committed by a state officer or employee, and the defendants' immunity was only lost if it was proved that the defendants' conduct was not within the scope of the defendants' official duties or employment. Gibbons v. McBride, 124 F. Supp. 3d 1342 (S.D. Ga. 2015).

Probation officer, employed by the county sheriff's office, who signed an arrest warrant for the nonpayment of a traffic fine after the arrestee had actually paid the fine, was not entitled to immunity under the Georgia Tort Claims Act, O.C.G.A. § 50-21-20 et seq., because the Act specifically excluded counties, and the officer was acting on the county's behalf and not on behalf or in the service of the state. Washington v. Rivera, 939 F.3d 1239 (11th Cir. 2019).

State official immune from tort liability for assumed intentional eavesdropping.

- Employee's suit against a supervisor at a state agency alleging illegal eavesdropping and invasion of privacy in violation of O.C.G.A. § 16-11-62 was dismissed based on immunity under O.C.G.A. §§ 50-21-21(b) and50-21-25(a); the supervisor was a state employee acting within the scope of the supervisor's employment when the supervisor answered the employee's accidental call and listened in on the employee's conversation with the employee's spouse, which was critical of the supervisor. Stephens v. Coan, 349 Ga. App. 147, 825 S.E.2d 525 (2019).

Discretionary function in deterinming discharge.

- Determination by a state hospital whether a mental patient was a candidate for discharge to a personal care home was a discretionary function. Northwest Ga. Regional Hosp. v. Wilkins, 220 Ga. App. 534, 469 S.E.2d 786 (1996).

Placement of children in foster home.

- Caseworker and supervisor in the Department of Family and Children Services acted within the scope of their official duties in the placement and supervision of children in a foster home and, thus, were entitled to official immunity. Miracle by Miracle v. Spooner, 978 F. Supp. 1161 (N.D. Ga. 1997).

Psychiatrist working for a state agency was entitled to immunity since the psychiatrist was sued only in an official capacity since the plaintiff never claimed that the psychiatrist treated the decedent as a private-pay patient. Board of Regents v. Frost, 233 Ga. App. 692, 505 S.E.2d 236 (1998).

Defendants were immune from liability in an action for wrongful termination from employment because the cause of action arose after the statute's effective date, the defendants were state employees, and the deferdants were both acting within the scope of the defendants' employment duties when they fired the plaintiff. Wang v. Moore, 247 Ga. App. 666, 544 S.E.2d 486 (2001).

Correctional officers entitled to immunity.

- Correctional officers' actions in requiring a student on a prison tour, who had disobeyed prison instructions, to do push-ups was within the scope of the officers' official duties as the officers were responsible to control the tour participants and to restrain and discipline any uncooperative participants by requiring push-ups and by using verbal means or physical force. Herndon v. Mosley, 257 Ga. App. 495, 571 S.E.2d 491 (2002).

Trial court properly denied the port authority employee's motion to dismiss the ship owner's claims for contribution or indemnity as a state law tort claim was prohibited against the employee for tortious acts committed while acting within the scope of employment and whether the employee was so acting was a question of fact which could not be resolved on a motion to dismiss the cross-claim for contribution or indemnity filed against the employee. Ga. Ports Auth. v. Andre Rickmers Schiffsbeteiligungsges mbH & Co. K.G., 262 Ga. App. 591, 585 S.E.2d 883 (2003).

Trial court incorrectly denied a prison official's motion for summary judgment on the estate administrators' state causes of action, following the death of an inmate who overdosed on Tylenol, because the administrators failed to prove that the official was acting outside the scope of the person's official duties or employment; consequently, even if the official acted with malice or intent to injure the decedent, the official was immune from liability on the administrators' state law claims against the official. Minor v. Barwick, 264 Ga. App. 327, 590 S.E.2d 754 (2003).

Allegations by the nursery owners that a state university professor acted intentionally or willfully did not remove the professor from the scope of the professor's state employment for purposes of the Georgia Tort Claims Act, O.C.G.A. § 50-21-20 et seq. (GTCA), and, thus, the state university professor was protected by sovereign immunity and the GTCA from liability arising out of claims about what would happen to certain royalties related to plant cuttings the nursery owners gave to the professor and which the professor concluded had vast commercial potential. Feist v. Dirr, 271 Ga. App. 169, 609 S.E.2d 111 (2004).

Merely styling a suit against a public officer as one brought against the officer personally does not deprive the officer of any immunity to which the officer might otherwise be entitled for the officer's official acts under the Georgia Tort Claims Act, O.C.G.A. § 50-21-20 et seq. Davis v. Standifer, 275 Ga. App. 769, 621 S.E.2d 852 (2005).

If a state employee acts in the prosecution of and within the scope of the employee's official duties, intentional wrongful conduct comes within and remains within the scope of employment, and even when a plaintiff alleges a state constitutional violation, if the underlying conduct complained of is tortious and occurred within the scope of the state employee's official duties, the employee is protected by official immunity under the Georgia Tort Claims Act, O.C.G.A. § 50-21-20 et seq. Davis v. Standifer, 275 Ga. App. 769, 621 S.E.2d 852 (2005).

Actions of state trooper.

- When a citizen alleged that a state trooper sexually assaulted the citizen during a traffic stop, the trooper was immune from liability under O.C.G.A. § 50-21-25(a) because the only alleged contact between the citizen and the trooper occurred during the traffic stop so any alleged assault would have occurred while the trooper was performing official duties, making the trooper immune from alleged state constitutional violations arising from the same facts. Davis v. Standifer, 275 Ga. App. 769, 621 S.E.2d 852 (2005).

Officer immune in suit.

- Trial court erred by entering a default judgment against a police officer for failing to timely answer because the officer was immune from suit on the claim brought under state law, thus, the default judgment entered on that claim was a nullity and the trial court lacked subject matter jurisdiction and should have dismissed the state law cause of action for lack of subject matter jurisdiction. Ferrell v. Young, 323 Ga. App. 338, 746 S.E.2d 167 (2013).

College campus police officers did not qualify for immunity.

- Campus police officers employed by a private college did not qualify as state officers or employees who may assert immunity from tort suits under the Georgia Tort Claims Act, O.C.G.A. § 50-21-20 et seq., because the officers were not acting for any state government entity when the officers committed the alleged torts. Hartley v. Agnes Scott College, 295 Ga. 458, 759 S.E.2d 857 (2014).

Dismissal of teachers.

- Because in meetings and at all other relevant times college officials were engaged in the performance of their official duties, under O.C.G.A. § 50-21-25(a), the officials had state tort immunity for statements the officials may have made at those meetings concerning the reasons for a teacher's dismissal, and for actions taken to effect the teacher's dismissal. Tootle v. Cartee, 280 Ga. App. 428, 634 S.E.2d 90 (2006).

Action based on determation.

- In a state employee's suit asserting defamation against a state director, the trial court properly granted the director summary judgment and dismissed the complaint as the records established that the director was a state employee at the time the alleged statements were made and, therefore, any libelous or slanderous statements were made by the director within the scope of the director's official duties and, thus, the director was immune from liability. Ford v. Caffrey, 293 Ga. App. 269, 666 S.E.2d 623 (2008).

Claims of excessive force.

- Based on O.C.G.A. § 9-2-61, an arrestee's excessive force claim against a sheriff's major in the major's individual capacity was revived after a voluntary dismissal but assuming that the complaint alleged actual malice under Ga. Const. 1983, Art. I, Sec. II, Para. IX(d), as to the major's conduct, the tort claim had to brought against the state under O.C.G.A. § 50-21-25(b); however, the state did not waive the state's sovereign immunity under O.C.G.A. § 50-21-23(b) for such claim to be brought in federal court. Jude v. Morrison, 534 F. Supp. 2d 1365 (N.D. Ga. 2008).

Plaintiff employee did not show that defendant school system waived the system's immunity, Ga. Const. 1983, Art. I, Sec. II, Para. IX(e), because the plaintiff pointed to no legislative act providing for a waiver. In addition, because the defendant superintendent was a state employee whose alleged tort was committed while acting within the scope of the superintendent's employment, the superintendent also was entitled to immunity, O.C.G.A. § 50-21-25(a). Polite v. Dougherty County Sch. Sys., F.3d (11th Cir. Aug. 11, 2008)(Unpublished).

Plaintiffs' tort claims against a SWAT member who shot and killed a barricaded gunman were barred by the Georgia Tort Claims Act because nothing in the complaint suggested that the member's conduct was outside the scope of the member's official duties or employment. Dixon v. Ga. Dep't of Pub. Safety, 135 F. Supp. 3d 1362 (S.D. Ga. 2015).

Actions by prison inmates.

- Trial court did not err in disallowing a prison inmate to file a conversion claim against a warden and corrections officers under the Georgia Tort Claims Act (GTCA), O.C.G.A. § 50-21-20 tet seq., because their actions were clothed with official immunity under the GTCA, O.C.G.A. § 50-21-25(b), since they were acting within the scope of their official duties when they confiscated the inmate's personal property; the inmate acknowledged that the Georgia Department of Corrections had to be named as a defendant, which necessarily amounted to a concession that Department employees were not proper defendants, and their alleged tortious conduct occurred while they were acting within the scope of their official duties. Romano v. Ga. Dep't of Corr., 303 Ga. App. 347, 693 S.E.2d 521 (2010).

Employee as commissioner and immunity.

- Grant of summary judgment on the ground that O.C.G.A. § 50-21-25(a) granted immunity was affirmed because the employee's testimony at trial was based upon actions taken while the employee was commissioner. Accordingly, the trial court properly granted summary judgment to the employee based upon the employee's immunity for acts taken within the scope of the employee's official duties. Douglas Asphalt Co. v. Linnenkohl, 320 Ga. App. 427, 741 S.E.2d 169 (2013).

Exclusive remedy.

- Georgia law waives sovereign immunity for tort suits against state officers and employees committed in the scope of employment under O.C.G.A. § 50-21-23, while a later statute, O.C.G.A. § 50-21-25, states that the procedure established under the Georgia Tort Claims Act provides the exclusive remedy for any tort committed by a state officer or employee under O.C.G.A. § 50-21-25(a). Nat'l Ass'n of Bds. of Pharm. v. Bd. of Regents, 633 F.3d 1297 (11th Cir. 2011).

Special master entitled to immunity.

- In a renter's suit asserting that the renter's due process rights were violated in connection with the renter's eviction after a bank's foreclosure on the property the renter was leasing, a special master who ruled in the renter's state court suit was immune from the renter's federal claims because the master was considered a judge for purposes of O.C.G.A. § 50-21-25. Vereen v. Everett, F. Supp. 2d (N.D. Ga. Mar. 31, 2009).

University employees entitled to immunity.

- Because two university workers acted within the scope of the workers' employment by following university policy in reporting an alleged inappropriate relationship between the workers' former boss and a university official, an invasion of privacy claim asserted against the workers by that former boss should have been dismissed since such was barred by the Georgia Tort Claims Act, O.C.G.A. § 50-21-20 et seq., and sovereign immunity. Massey v. Roth, 290 Ga. App. 496, 659 S.E.2d 872 (2008).

State employed physician entitled to official immunity.

- Trial court properly granted summary judgment to a prison doctor in a medical malpractice action on behalf of a deceased patient/inmate as the doctor worked for the Board of Regents of the University System of Georgia, rather than for the Georgia Department of Corrections, and the doctor was not a proper party defendant under O.C.G.A. § 50-21-25 as the Board should have been served and named as the proper party. Green v. Cent. State Hosp., 275 Ga. App. 569, 621 S.E.2d 491 (2005).

Under O.C.G.A. § 50-21-25(a), a state-employed physician was entitled to official immunity from medical malpractice actions brought by patients whose treatment was paid for by public funds when the doctor's treatment fell within the scope of the doctor's duties as a state employee. Porter v. Guill, 298 Ga. App. 782, 681 S.E.2d 230 (2009).

Physician, who was a second-year fellow at the Medical College of Georgia Children's Medical Center's Graduate Medical Education Program, was entitled to official immunity in a medical malpractice action under Ga. Const.1983, Art. I, Sec. II, Para. IX(d) and O.C.G.A. § 50-21-25(b) because the physician, who provided followup medical treatment to a child, was operating under the general supervision of an attending physician who was a faculty member and an employee of the Medical College of Georgia. Jones v. Allen, 312 Ga. App. 762, 720 S.E.2d 1 (2011).

In a medical malpractice suit, two physicians were entitled to official immunity under O.C.G.A. §§ 50-21-23(b) and50-21-25(a) because the record established that the physicians were full-time faculty members at a Georgia medical college performing the physicians' regular duties of employment at the time the estate's decedent was allegedly injured. Cook v. Forrester, 323 Ga. App. 631, 746 S.E.2d 624 (2013).

State employed resident physicians entitled to official immunity.

- In a medical malpractice action against a hospital and four residents, the residents were entitled to qualified immunity under O.C.G.A. § 50-21-25(a) because state-employed resident physicians were entitled to immunity from liability arising from the residents' treatment of patients during the course of the medical residency. Nelson v. Bd. of Regents of the Univ. Sys. of Ga., 307 Ga. App. 220, 704 S.E.2d 868 (2010).

Physician whose license was temporarily suspended could not file suit against officers of the Board of Medical Examiners or other state employees for their actions relating to the suspension. Howard v. Miller, 222 Ga. App. 868, 476 S.E.2d 636 (1996).

Two physicians, who were faculty members at the Medical College of Georgia Children's Medical Center, did not establish in a medical malpractice action that the physicians were entitled to qualified immunity under Ga. Const. 1983, Art. I, Sec. II, Para. IX(d) and O.C.G.A. § 50-21-25(b), because the child whom the physicians treated at the center was a private pay patient. Notwithstanding the physicians' official duties as faculty members, when they acted as physicians, the physicians' primary duty was to the child, rather than to the State of Georgia. Jones v. Allen, 312 Ga. App. 762, 720 S.E.2d 1 (2011).

Physicians employed by state medical college.

- Georgia Supreme Court overruled Keenan v. Plouffe, 267 Ga. 791, (1997) and holds that the analysis of a physician's official immunity under the Georgia Tort Claims Act, O.C.G.A. § 50-21-20 et seq., shall proceed exclusively on the basis of whether the physician was acting within the scope of the physician's state employment in performing the treatment that is the subject of the malpractice action. Shekhawat v. Jones, 293 Ga. 468, 746 S.E.2d 89 (2013).

Two physicians were entitled to official immunity in a medical malpractice suit brought against the physicians by the parents of a newborn infant injured by the medical team's failure to ensure the child was adequately oxygenated during intubation because the physicians were acting within the scope of the physicians state employment at the Medical College of Georgia in rendering the medical care at issue. However, the effect of recognizing official immunity does not necessarily leave the injured plaintiff without recourse as, while official immunity relieves the state employee of personal liability, the injured plaintiff may still seek relief against the state government entity for which the state officer or employee was acting, pursuant to the Georgia Tort Claims Act, O.C.G.A. §§ 50-21-23 and50-21-25(b). Shekhawat v. Jones, 293 Ga. 468, 746 S.E.2d 89 (2013).

Cause of action under statute precluded federal due process claim.

- If a county sheriff's investigator and another county official actively participated in the theft of an arrestee's property, then the arrestee was free to pursue a tort cause of action against those officials under Georgia law; consequently, the arrestee's allegations did not state a claim for relief under the due process clause of U.S. Const., amend. 14, given that state law provided an adequate remedy for the alleged theft of the arrestee's property. Shouse v. Ursitti, F. Supp. 2d (M.D. Ga. May 23, 2006).

Commissioner of Department of Human Resources was entitled to immunity under the Tort Claims Act, O.C.G.A. § 50-21-20 et seq. Dollar v. Olmstead, 232 Ga. App. 520, 502 S.E.2d 472 (1998).

University administrators entitled to immunity.

- Despite allegations that the university's actions in denying tenure to the plaintiff were motivated by malice and ill-intent, the defendants' actions were squarely within the confines of the defendants' official duties as university administrators, and the defendants were entitled to immunity under the Georgia Tort Claims Act, O.C.G.A. § 50-21-20 et seq. Hardin v. Phillips, 249 Ga. App. 541, 547 S.E.2d 565 (2001).

Because a university president failed to show an enforceable employment contract, there was no waiver of sovereign immunity on the basis of a written contract. The president's tort claims against the State and Board of Regents were exclusively governed and barred by the Georgia Tort Claims Act, and the president could not invoke the Georgia Racketeer Influenced and Corrupt Organizations Act, O.C.G.A. § 16-14-1 et seq., as an alternative remedy. Tricoli v. Watts, 336 Ga. App. 837, 783 S.E.2d 475 (2016).

Supervisor for state was immune from personal liability for an alleged intentional or malicious tort committed in the performance of the supervisor's official duties; there was no exemption from O.C.G.A. § 50-21-25(a) for acts motivated by malice or an intent to injure. Ridley v. Johns, 274 Ga. 241, 552 S.E.2d 853 (2001).

Community service boards not part of DHR.

- Legislature did not intend for community service boards to be part of the Department of Human Resources (DHR) or its employees to be department employees, under ordinary circumstances; a suit claiming that DHR was liable for the alleged negligence of a board employee should have been dismissed. Dep't of Human Res. v. Crews, 278 Ga. App. 56, 628 S.E.2d 191 (2006).

Inmate's state law battery claim against a correctional officer was barred because it was clear from the complaint that the alleged battery arose from the officer's official duties. Mattox v. Bailey, 221 Ga. App. 546, 472 S.E.2d 130 (1996).

Notice held adequate despite being provided to incorrect agency.

- Trial court erred by dismissing a plaintiff's negligence complaint since the plaintiff complied with the plain language of the ante litem notice provision of the Georgia Tort Claims Act (GTCA), O.C.G.A. § 50-21-26, even though, due to error on the plaintiff's part, the actual responsible agency was not provided with ante litem notice within the 12-month period; there was no evidence that the State of Georgia suffered any prejudice therefrom. Cummings v. Ga. Dep't of Juvenile Justice, 282 Ga. 822, 653 S.E.2d 729 (2007).

Self-contradictory testimony rule.

- In a wrongful death action against the Georgia Department of Public Safety in which the decedent died from injuries sustained in a high-speed chase with the Georgia State Patrol officers, the decedent's daughter offered no argument or authority for the proposition that the self-contradictory testimony rule should apply to the testimony of non-party witnesses, including the primary and secondary pursuing officers, because the Department was the party being sued, not the officers. James v. Ga. Dep't of Pub. Safety, 337 Ga. App. 864, 789 S.E.2d 236 (2016).

Cited in McGee v. State, 227 Ga. App. 107, 487 S.E.2d 671 (1997); Ga. Dep't of Human Res. v. Coley, 247 Ga. App. 392, 544 S.E.2d 165 (2000); McCall v. Dep't of Human Res., 176 F. Supp. 2d 1355 (M.D. Ga. 2001); Fedorov v. Bd. of Regents, 194 F. Supp. 2d 1378 (S.D. Ga. 2002); Nat'l Ass'n of Bds. of Pharm. v. Bd. of Regents of the Univ. Sys. of Ga., F. Supp. 2d (M.D. Ga. Apr. 18, 2008); Considine v. Murphy, 297 Ga. 164, 773 S.E.2d 176 (2015).

RESEARCH REFERENCES

ALR.

- Liability of municipality or other governmental unit for failure to provide police protection from crime, 90 A.L.R.5th 273.

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