default rule (Georgia) · Go Syfert
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default rule in Georgia

14 Georgia opinions name it 2 courts 1962–2026 7 in the last five years

The cases below were cited by Georgia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Wasserman v. Franklin Countygreen
ga · 2025 · cited in 4 Georgia opinions naming this issue, 2025–2025
2 sentences

2025“When we consider whether to follow one of our past decisions, stare decisis is the strong default rule.” Wasserman, 320 Ga. at 645 (II) (B) (1) (citation and punctuation omitted).

2025When we are asked to reconsider and overrule one of our prior decisions, “stare decisis is the strong default rule.” Wasserman v. Franklin County, 320 Ga. 624, 645 (2025) (cleaned up).

44
Johnson v. Stategreen
ga · 2023 · cited in 2 Georgia opinions naming this issue, 2025–2025
2 sentences

2025As we have stated, “[w]hen we consider whether to follow past decisions, stare decisis is the strong default rule.” Johnson v. State, 315 Ga. 876, 887 (3) ( 885 SE2d 725 ) (2023).

2025As we have stated, “[w]hen we consider whether to follow past decisions, stare decisis is the strong default rule.” Johnson v. State, 315 Ga. 876, 887 (3) ( 885 SE2d 725 ) (2023).

22
Newborn v. Claygreen
ga · 1993 · cited in 1 Georgia opinions naming this issue, 2026–2026
2 sentences

2026This Court also addressed the lack of specificity in the December 15 order regarding the real estate parcels, citing Newborn v. Clay, 263 Ga. 622, 623 ( 436 SE2d 654 ) (1993) (explaining a default rule for real property in divorce proceedings), noting that on remand the court “may wish to clarify what real property” must be sold.

2026This Court also addressed the lack of specificity in the December 15 order regarding the real estate parcels, citing Newborn v. Clay, 263 Ga. 622, 623 ( 436 SE2d 654 ) (1993) (explaining a default rule for real property in divorce proceedings), noting that on remand the court “may wish to clarify what real property” must be sold.

11
Water Visions International, Inc. v. Tippett Clepper Associates, Inc.green
gactapp · 2008 · cited in 1 Georgia opinions naming this issue, 2023–2023
2 sentences

2023In order to present a meritorious defense, a defendant must “set forth facts that show the existence of the essential elements of such defense even though there is no requirement that the affidavit or other sworn statement contain in great detail the factual basis of the proposed defense.”5 Put another way, a defendant meets this 4 OCGA § 9-11-55 (b). 5 Water Visions Int’l, Inc. v. Tippett Clepper Assocs., Inc., 293 Ga. App. 285, 287 (2) ( 666 SE2d 628 ) (2008) (punctuation omitted); see Exxon Corp. v. Thomason, 269 Ga. 761, 761 (1) ( 504 SE2d 676 ) (1998) (“One of the requirements for the ope

2023In order to present a meritorious defense, a defendant must “set forth facts that show the existence of the essential elements of such defense even though there is no requirement that the affidavit or other sworn statement contain in great detail the factual basis of the proposed defense.”5 Put another way, a defendant meets this 4 OCGA § 9-11-55 (b). 5 Water Visions Int’l, Inc. v. Tippett Clepper Assocs., Inc., 293 Ga. App. 285, 287 (2) ( 666 SE2d 628 ) (2008) (punctuation omitted); see Exxon Corp. v. Thomason, 269 Ga. 761, 761 (1) ( 504 SE2d 676 ) (1998) (“One of the requirements for the ope

11
Exxon Corp. v. Thomasongreen
ga · 1998 · cited in 1 Georgia opinions naming this issue, 2023–2023
2 sentences

2023In order to present a meritorious defense, a defendant must “set forth facts that show the existence of the essential elements of such defense even though there is no requirement that the affidavit or other sworn statement contain in great detail the factual basis of the proposed defense.”5 Put another way, a defendant meets this 4 OCGA § 9-11-55 (b). 5 Water Visions Int’l, Inc. v. Tippett Clepper Assocs., Inc., 293 Ga. App. 285, 287 (2) ( 666 SE2d 628 ) (2008) (punctuation omitted); see Exxon Corp. v. Thomason, 269 Ga. 761, 761 (1) ( 504 SE2d 676 ) (1998) (“One of the requirements for the ope

2023In order to present a meritorious defense, a defendant must “set forth facts that show the existence of the essential elements of such defense even though there is no requirement that the affidavit or other sworn statement contain in great detail the factual basis of the proposed defense.”5 Put another way, a defendant meets this 4 OCGA § 9-11-55 (b). 5 Water Visions Int’l, Inc. v. Tippett Clepper Assocs., Inc., 293 Ga. App. 285, 287 (2) ( 666 SE2d 628 ) (2008) (punctuation omitted); see Exxon Corp. v. Thomason, 269 Ga. 761, 761 (1) ( 504 SE2d 676 ) (1998) (“One of the requirements for the ope

11
Lucas v. Integrated Health Services of Lester, Inc.green
gactapp · 2004 · cited in 1 Georgia opinions naming this issue, 2023–2023
2 sentences

2023In order to present a meritorious defense, a defendant must “set forth facts that show the existence of the essential elements of such defense even though there is no requirement that the affidavit or other sworn statement contain in great detail the factual basis of the proposed defense.”5 Put another way, a defendant meets this 4 OCGA § 9-11-55 (b). 5 Water Visions Int’l, Inc. v. Tippett Clepper Assocs., Inc., 293 Ga. App. 285, 287 (2) ( 666 SE2d 628 ) (2008) (punctuation omitted); see Exxon Corp. v. Thomason, 269 Ga. 761, 761 (1) ( 504 SE2d 676 ) (1998) (“One of the requirements for the ope

2023In order to present a meritorious defense, a defendant must “set forth facts that show the existence of the essential elements of such defense even though there is no requirement that the affidavit or other sworn statement contain in great detail the factual basis of the proposed defense.”5 Put another way, a defendant meets this 4 OCGA § 9-11-55 (b). 5 Water Visions Int’l, Inc. v. Tippett Clepper Assocs., Inc., 293 Ga. App. 285, 287 (2) ( 666 SE2d 628 ) (2008) (punctuation omitted); see Exxon Corp. v. Thomason, 269 Ga. 761, 761 (1) ( 504 SE2d 676 ) (1998) (“One of the requirements for the ope

11
UNITED HEALTH SERVICES OF GEORGIA, INC. Et Al. v. ALEXANDER Et Al.green
gactapp · 2017 · cited in 1 Georgia opinions naming this issue, 2020–2020
1 sentence

2020Hence, those cases simply set out a default rule that no specific form of arbitration award is required, but because arbitration is a matter of contract, see United Health Svcs. of Ga., 342 Ga. App. at 2 (2), parties are free to contact around that default rule, unless prohibited by statute or public policy.

11
RSN Properties, Inc. v. Engineering Consulting Services, Ltd.green
gactapp · 2009 · cited in 1 Georgia opinions naming this issue, 2020–2020
2 sentences

2020See RSN Properties v. Engineering Consulting Svcs., 301 Ga. App. 52, 53 ( 686 SE2d 853 ) (2009) (“Unless prohibited by statute or public policy, the parties to a contract are free to contract on any terms and about any subject matter in which they have an interest.”) (citation and punctuation omitted).

2020See RSN Properties v. Engineering Consulting Svcs., 301 Ga. App. 52, 53 ( 686 SE2d 853 ) (2009) (“Unless prohibited by statute or public policy, the parties to a contract are free to contract on any terms and about any subject matter in which they have an interest.”) (citation and punctuation omitted).

11
Ruffin v. Stategreen
ga · 2008 · cited in 1 Georgia opinions naming this issue, 2010–2010
2 sentences

2010See Ruffin v. State, 284 Ga. 52, 61 (2)(b)(ii), 663 S.E.2d 189 (2008) (for speedy trial purposes, the State "includes all state actors, even trial and appellate court judges"). [5] Though appellant asserts that the delay has hampered his ability to investigate whether counsel was deficient in failing to raise a challenge to the State's use of peremptory strikes under Batson v. Kentucky, 476 U.S. 79 , 106 S.Ct. 1712 , 90 L.Ed.2d 69 (1986), we note that Batson was not decided until after appellant's trial.

2010See Ruffin v. State, 284 Ga. 52, 61 (2) (b) (ii) ( 663 SE2d 189 ) (2008) (for speedy trial purposes, the State “includes all state actors, even trial and appellate court judges”).

11
Batson v. Kentuckygreen
scotus · 1986 · cited in 1 Georgia opinions naming this issue, 2010–2010
2 sentences

2010See Ruffin v. State, 284 Ga. 52, 61 (2)(b)(ii), 663 S.E.2d 189 (2008) (for speedy trial purposes, the State "includes all state actors, even trial and appellate court judges"). [5] Though appellant asserts that the delay has hampered his ability to investigate whether counsel was deficient in failing to raise a challenge to the State's use of peremptory strikes under Batson v. Kentucky, 476 U.S. 79 , 106 S.Ct. 1712 , 90 L.Ed.2d 69 (1986), we note that Batson was not decided until after appellant's trial.

2010See Ruffin v. State, 284 Ga. 52, 61 (2)(b)(ii), 663 S.E.2d 189 (2008) (for speedy trial purposes, the State "includes all state actors, even trial and appellate court judges"). [5] Though appellant asserts that the delay has hampered his ability to investigate whether counsel was deficient in failing to raise a challenge to the State's use of peremptory strikes under Batson v. Kentucky, 476 U.S. 79 , 106 S.Ct. 1712 , 90 L.Ed.2d 69 (1986), we note that Batson was not decided until after appellant's trial.

11
Ruffin v. Stategreen
ga · 2008 · cited in 1 Georgia opinions naming this issue, 2010–2010
2 sentences

2010See Ruffin v. State, 284 Ga. 52, 61 (2)(b)(ii), 663 S.E.2d 189 (2008) (for speedy trial purposes, the State "includes all state actors, even trial and appellate court judges"). [5] Though appellant asserts that the delay has hampered his ability to investigate whether counsel was deficient in failing to raise a challenge to the State's use of peremptory strikes under Batson v. Kentucky, 476 U.S. 79 , 106 S.Ct. 1712 , 90 L.Ed.2d 69 (1986), we note that Batson was not decided until after appellant's trial.

2010See Ruffin v. State, 284 Ga. 52, 61 (2) (b) (ii) ( 663 SE2d 189 ) (2008) (for speedy trial purposes, the State “includes all state actors, even trial and appellate court judges”).

11
Robinson-Shamburger, Inc. v. Tenneygreen
gactapp · 1975 · cited in 1 Georgia opinions naming this issue, 1988–1988
1 sentence

1988As to whether defendant was a proper party, “[a]s far as the law is concerned, by [its] failure to answer, [it] has had [its] day in court.” Robinson-Shamburger, Inc. v. Tenney, 135 Ga. App. 131, 134 ( 217 SE2d 184 ) (1975).

11
Blanch v. Kinggreen
ga · 1947 · cited in 1 Georgia opinions naming this issue, 1978–1978
2 sentences

1978Under all notice pleadings under the Civil Practice Act parties are no longer bound to take notice of the time and place of trial and when their presence is required under the older cases of Blanch v. King, 202 Ga. 779, 783 ( 44 SE2d 779 ); and Williams v. Linn, 108 Ga. App. 629, 633 (3) ( 133 SE2d 892 ), and service must be made upon the attorney unless service upon the party himself is ordered by the court.

1978Under all notice pleadings under the Civil Practice Act parties are no longer bound to take notice of the time and place of trial and when their presence is required under the older cases of Blanch v. King, 202 Ga. 779, 783 ( 44 SE2d 779 ); and Williams v. Linn, 108 Ga. App. 629, 633 (3) ( 133 SE2d 892 ), and service must be made upon the attorney unless service upon the party himself is ordered by the court.

11
Liberty Forest Products, Inc. v. Interstate Paper Corp.green
gactapp · 1976 · cited in 1 Georgia opinions naming this issue, 1978–1978
2 sentences

1978Every pleading subsequent to the original complaint and "every written notice, appearance, demand . . . shall be served upon each of the parties” unless there be a default and waiver of all notices, "including notices of time and place of trial.” Code Ann. § 81A-105 (a) (Ga. L. 1966, pp. 609,615; 1967, pp. 226,229); Liberty Forest Products v. Interstate Paper Corp., 138 Ga. App. 153, 154 ( 225 SE2d 731 ).

1978Every pleading subsequent to the original complaint and "every written notice, appearance, demand . . . shall be served upon each of the parties” unless there be a default and waiver of all notices, "including notices of time and place of trial.” Code Ann. § 81A-105 (a) (Ga. L. 1966, pp. 609,615; 1967, pp. 226,229); Liberty Forest Products v. Interstate Paper Corp., 138 Ga. App. 153, 154 ( 225 SE2d 731 ).

11
Williams v. Linngreen
gactapp · 1963 · cited in 1 Georgia opinions naming this issue, 1978–1978
2 sentences

1978Under all notice pleadings under the Civil Practice Act parties are no longer bound to take notice of the time and place of trial and when their presence is required under the older cases of Blanch v. King, 202 Ga. 779, 783 ( 44 SE2d 779 ); and Williams v. Linn, 108 Ga. App. 629, 633 (3) ( 133 SE2d 892 ), and service must be made upon the attorney unless service upon the party himself is ordered by the court.

1978Under all notice pleadings under the Civil Practice Act parties are no longer bound to take notice of the time and place of trial and when their presence is required under the older cases of Blanch v. King, 202 Ga. 779, 783 ( 44 SE2d 779 ); and Williams v. Linn, 108 Ga. App. 629, 633 (3) ( 133 SE2d 892 ), and service must be made upon the attorney unless service upon the party himself is ordered by the court.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Georgia. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
Mitsui Marine & Fire Ins. Co. v. Hanjin Shipping Co. Ltd. neutral
gactapp · 2006
1 sentence

2025Co., Ltd. v. Hanjin Shipping Co., Ltd., 279 Ga. App. 689 , 694 n. 16 (2006) (explaining that despite the “bright line default rule,” future parties could negotiate around this rule by “explicitly stating” that the parties were not bound by it).

12025–2025
McClure v. Gower green
ga · 1989
1 sentence

2020Two years later, in McClure v. Gower, 259 Ga. 678 ( 385 SE2d 271 ) (1989), we examined OCGA § 51-12-5.1, noting that it “sets forth substantive and procedural rules to govern punitive-damage awards in tort actions in this state.” Id. at 681.

12020–2020
City of Atlanta v. Barnes red
ga · 2003
2 sentences

2010Id. at 453 , 578 S.E.2d 110 .

2010Id. at 453 , 578 S.E.2d 110 .

12010–2010
Calloway v. Harms green
gactapp · 1975
1 sentence

1988As to whether defendant was a proper party, “[a]s far as the law is concerned, by [its] failure to answer, [it] has had [its] day in court.” Robinson-Shamburger, Inc. v. Tenney, 135 Ga. App. 131, 134 ( 217 SE2d 184 ) (1975).

11988–1988
Peacock v. Walker green
ga · 1957
2 sentences

1962But even if we are incorrect in this conclusion and the default judgment rule applies to garnishment proceedings (see Potts v. Smith Grain Co., 99 Ga. App. 270 , 108 SE2d 285 ; Peacock v. Walker, 213 Ga. 628 , 100 SE2d 575 ) in this case the judgment was not taken against the garnishee within a 15-day period in which a garnishee might have had a right to open the default as a matter of law, but the judgment in this case was taken several terms after the time at which the garnishee was directed to file his answer.

1962But even if we are incorrect in this conclusion and the default judgment rule applies to garnishment proceedings (see Potts v. Smith Grain Co., 99 Ga. App. 270 , 108 SE2d 285 ; Peacock v. Walker, 213 Ga. 628 , 100 SE2d 575 ) in this case the judgment was not taken against the garnishee within a 15-day period in which a garnishee might have had a right to open the default as a matter of law, but the judgment in this case was taken several terms after the time at which the garnishee was directed to file his answer.

11962–1962
Potts v. SMITH GRAIN COMPANY, INC. green
gactapp · 1959
2 sentences

1962But even if we are incorrect in this conclusion and the default judgment rule applies to garnishment proceedings (see Potts v. Smith Grain Co., 99 Ga. App. 270 , 108 SE2d 285 ; Peacock v. Walker, 213 Ga. 628 , 100 SE2d 575 ) in this case the judgment was not taken against the garnishee within a 15-day period in which a garnishee might have had a right to open the default as a matter of law, but the judgment in this case was taken several terms after the time at which the garnishee was directed to file his answer.

1962But even if we are incorrect in this conclusion and the default judgment rule applies to garnishment proceedings (see Potts v. Smith Grain Co., 99 Ga. App. 270 , 108 SE2d 285 ; Peacock v. Walker, 213 Ga. 628 , 100 SE2d 575 ) in this case the judgment was not taken against the garnishee within a 15-day period in which a garnishee might have had a right to open the default as a matter of law, but the judgment in this case was taken several terms after the time at which the garnishee was directed to file his answer.

11962–1962

Statutes the citing opinions construe

GA § 51-12-5.1 (3) GA § 9-4-2 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 289 (1929–2026) TX 115 (1977–2026) IL 83 (1911–2026) FL 60 (1970–2026) DE 51 (1996–2026) NY 49 (1938–2026) WA 44 (1909–2025) OH 41 (1998–2026) PA 38 (1927–2026) MI 31 (2007–2025) CT 30 (1991–2026) AZ 28 (1969–2024) IA 28 (1976–2026) MO 27 (1986–2025) OR 26 (1909–2025) LA 26 (1982–2025) DC 22 (2001–2026) WI 22 (1997–2024) MD 22 (1986–2025) UT 18 (2002–2022) MA 17 (1927–2025) NC 16 (1896–2026) NJ 16 (1952–2025) VA 15 (1989–2025) GA 14 (1962–2026) MN 14 (1982–2025) MS 14 (1999–2024) CO 13 (1974–2026) AL 13 (1987–2023) NM 13 (1983–2023) SD 11 (1985–2024) IN 10 (1969–2025) AK 10 (1976–2025) ME 9 (1968–2022) MT 9 (1978–2016) ID 8 (1908–2025) WY 8 (2002–2025) ND 8 (1981–2014) KS 7 (2006–2026) HI 6 (1999–2024) SC 6 (2001–2025) KY 5 (2005–2024) NH 5 (1982–2025) TN 5 (1952–2020) NE 4 (1990–2024) OK 4 (2015–2022) WV 4 (2014–2024) NV 2 (2000–2025) RI 2 (2010–2010)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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