ten-day notice requirement (Georgia) · Go Syfert
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ten-day notice requirement in Georgia

11 Georgia opinions name it 2 courts 1977–2016 0 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 (9)

CaseFollowedCited
Welch v. Ford Motor Credit Co.green
gactapp · 1997 · cited in 3 Georgia opinions naming this issue, 2009–2013
2 sentences

2013And “a voluntary surrender of an automobile will trigger the ten-day notice requirement so long as, at the time the debtor surrendered the vehicle, the debtor was in default and the creditor had the right to repossess the vehicle.” (Citations and punctuation omitted.) Welch v. Ford Motor Credit Co., 227 Ga. App. 904, 905 ( 490 SE2d 206 ) (1997).

2013And “a voluntary surrender of an automobile will trigger the ten-day notice requirement so long as, at the time the debtor surrendered the vehicle, the debtor was in default and the creditor had the right to repossess the vehicle.” (Citations and punctuation omitted.) Welch v. Ford Motor Credit Co., 227 Ga. App. 904, 905 ( 490 SE2d 206 ) (1997).

33
Thaxton v. Stategreen
ga · 1990 · cited in 2 Georgia opinions naming this issue, 1993–1998
2 sentences

1998Thaxton v. State, 260 Ga. 141, 144 (6) ( 390 SE2d 841 ) (1990).

1998Thaxton v. State, 260 Ga. 141, 144 (6) ( 390 SE2d 841 ) (1990).

22
Earp v. Harrisgreen
gactapp · 1989 · cited in 1 Georgia opinions naming this issue, 2015–2015
2 sentences

2015See also Earp v. Harris, 191 Ga. App. 414, 416 ( 382 SE2d 156 ) (1989) (the trial court erred in finding that a driver’s family emergency, which required that he travel to another state to take care of his daughter following surgery, was a legal excuse for failing to timely request a hearing, where there was no evidence that the driver suffered from a disability that rendered him incapable *625 of requesting an administrative hearing within ten days as afforded by the statute) (applying former OCGA § 40-5-55).

2015See also Earp v. Harris, 191 Ga. App. 414, 416 ( 382 SE2d 156 ) (1989) (the trial court erred in finding that a driver’s family emergency, which required that he travel to another state to take care of his daughter following surgery, was a legal excuse for failing to timely request a hearing, where there was no evidence that the driver suffered from a disability that rendered him incapable *625 of requesting an administrative hearing within ten days as afforded by the statute) (applying former OCGA § 40-5-55).

11
Davis v. Browngreen
gactapp · 2005 · cited in 1 Georgia opinions naming this issue, 2015–2015
1 sentence

2015Compare Davis v. Brown, 274 Ga. App. at 51 (2) (the superior court properly set aside the suspension of the driver’s license where the evidence showed that an officer at the jail confiscated the driver’s copy of the suspension notice, which authorized the court to find that events out of the driver’s control prevented him from making a timely request and, therefore, the Department acted arbitrarily and capriciously in applying the ten-day notice requirement).

11
State v. Tiraboschigreen
ga · 1998 · cited in 1 Georgia opinions naming this issue, 2010–2010
2 sentences

2010In 2009, however, the legislature amended OCGA § 17-6-71 (a) to add that “[s]uch ten-day notice shall be adhered to strictly.” We presume “that the legislature knows and enacts statutes with reference to the existing law.” Hughes v. Ga. Dept. of Corrections, 267 Ga. App. 440, 442 (1) ( 600 SE2d 383 ) (2004); see also State v. Tiraboschi, 269 Ga. 812, 814 ( 504 SE2d 689 ) (1998).

2010In 2009, however, the legislature amended OCGA § 17-6-71 (a) to add that “[s]uch ten-day notice shall be adhered to strictly.” We presume “that the legislature knows and enacts statutes with reference to the existing law.” Hughes v. Ga. Dept. of Corrections, 267 Ga. App. 440, 442 (1) ( 600 SE2d 383 ) (2004); see also State v. Tiraboschi, 269 Ga. 812, 814 ( 504 SE2d 689 ) (1998).

11
Classic City Bonding Co. v. Stategreen
gactapp · 2002 · cited in 1 Georgia opinions naming this issue, 2010–2010
2 sentences

2010We have previously held that the ten-day notice requirement could be satisfied by the State’s “substantial compliance.” Northeast Atlanta Surety Co. v. Perdue, 294 Ga. App. 32 ( 668 SE2d 508 ) (2008) (sufficient notice given 22 days after failure to appear); Classic City Bonding Co. v. State of Ga., 256 Ga. App. 577, 578 ( 568 SE2d 834 ) (2002) (sufficient notice given 12 days after failure to appear); AAA Bonding Co. v. State of Ga., 192 Ga. App. 684, 685 (2) ( 386 SE2d 50 ) (1989) (statute then required notice within 72 hours of failure to appear; notice sent five days after failure was suff

2010We have previously held that the ten-day notice requirement could be satisfied by the State’s “substantial compliance.” Northeast Atlanta Surety Co. v. Perdue, 294 Ga. App. 32 ( 668 SE2d 508 ) (2008) (sufficient notice given 22 days after failure to appear); Classic City Bonding Co. v. State of Ga., 256 Ga. App. 577, 578 ( 568 SE2d 834 ) (2002) (sufficient notice given 12 days after failure to appear); AAA Bonding Co. v. State of Ga., 192 Ga. App. 684, 685 (2) ( 386 SE2d 50 ) (1989) (statute then required notice within 72 hours of failure to appear; notice sent five days after failure was suff

11
AAA BONDING COMPANY v. State of Georgiagreen
gactapp · 1989 · cited in 1 Georgia opinions naming this issue, 2010–2010
2 sentences

2010We have previously held that the ten-day notice requirement could be satisfied by the State’s “substantial compliance.” Northeast Atlanta Surety Co. v. Perdue, 294 Ga. App. 32 ( 668 SE2d 508 ) (2008) (sufficient notice given 22 days after failure to appear); Classic City Bonding Co. v. State of Ga., 256 Ga. App. 577, 578 ( 568 SE2d 834 ) (2002) (sufficient notice given 12 days after failure to appear); AAA Bonding Co. v. State of Ga., 192 Ga. App. 684, 685 (2) ( 386 SE2d 50 ) (1989) (statute then required notice within 72 hours of failure to appear; notice sent five days after failure was suff

2010We have previously held that the ten-day notice requirement could be satisfied by the State’s “substantial compliance.” Northeast Atlanta Surety Co. v. Perdue, 294 Ga. App. 32 ( 668 SE2d 508 ) (2008) (sufficient notice given 22 days after failure to appear); Classic City Bonding Co. v. State of Ga., 256 Ga. App. 577, 578 ( 568 SE2d 834 ) (2002) (sufficient notice given 12 days after failure to appear); AAA Bonding Co. v. State of Ga., 192 Ga. App. 684, 685 (2) ( 386 SE2d 50 ) (1989) (statute then required notice within 72 hours of failure to appear; notice sent five days after failure was suff

11
Hughes v. Georgia Department of Correctionsgreen
gactapp · 2004 · cited in 1 Georgia opinions naming this issue, 2010–2010
2 sentences

2010In 2009, however, the legislature amended OCGA § 17-6-71 (a) to add that “[s]uch ten-day notice shall be adhered to strictly.” We presume “that the legislature knows and enacts statutes with reference to the existing law.” Hughes v. Ga. Dept. of Corrections, 267 Ga. App. 440, 442 (1) ( 600 SE2d 383 ) (2004); see also State v. Tiraboschi, 269 Ga. 812, 814 ( 504 SE2d 689 ) (1998).

2010In 2009, however, the legislature amended OCGA § 17-6-71 (a) to add that “[s]uch ten-day notice shall be adhered to strictly.” We presume “that the legislature knows and enacts statutes with reference to the existing law.” Hughes v. Ga. Dept. of Corrections, 267 Ga. App. 440, 442 (1) ( 600 SE2d 383 ) (2004); see also State v. Tiraboschi, 269 Ga. 812, 814 ( 504 SE2d 689 ) (1998).

11
Willis v. Stategreen
gactapp · 1992 · cited in 1 Georgia opinions naming this issue, 1993–1993
2 sentences

1993“Although Rule 31.1 requires the notice to be filed at least 10 days before the trial, it authorizes the exercise of a trial court’s discretion by providing that the trial court may shorten or lengthen the time for compliance with the rule. [Cit.]” Thaxton v. State, 260 Ga. 141, 144 (6) ( 390 SE2d 841 ) (1990); Willis v. State, 202 Ga. App. 447, 449 (2) ( 414 SE2d 681 ) (1992).

1993“Although Rule 31.1 requires the notice to be filed at least 10 days before the trial, it authorizes the exercise of a trial court’s discretion by providing that the trial court may shorten or lengthen the time for compliance with the rule. [Cit.]” Thaxton v. State, 260 Ga. 141, 144 (6) ( 390 SE2d 841 ) (1990); Willis v. State, 202 Ga. App. 447, 449 (2) ( 414 SE2d 681 ) (1992).

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 (5)

CaseCitedYears
Jackson v. State green
ga · 1996
2 sentences

2016To the contrary, the Court began its analysis of Jackson’s due process claim by saying, “Although he had not complied with the ten-day notice requirement of Uniform Superior Court Rules 31.1 and 31.4, Jackson sought to raise the issue of his insanity,” Jackson, 267 Ga. at 132 – even though under Abernathy, Jackson was not required to comply with that notice requirement. 3 and (b) (requiring a defendant to provide pretrial notice of intent to introduce “expert evidence relating to a mental disease or defect or any other mental condition of the defendant” bearing on the issue of guilt in any cas

2016To the contrary, the Court began its analysis of Jackson’s due process claim by saying, “Although he had not complied with the ten-day notice requirement of [USCR] 31.1 and 31.4, Jackson sought to raise the issue of his insanity,” Jackson, 267 Ga. at 132 - even though under Abernathy, Jackson was not required to comply with that notice requirement.

12016–2016
Northeast Atlanta Surety Co. v. Perdue green
gactapp · 2008
2 sentences

2010We have previously held that the ten-day notice requirement could be satisfied by the State’s “substantial compliance.” Northeast Atlanta Surety Co. v. Perdue, 294 Ga. App. 32 ( 668 SE2d 508 ) (2008) (sufficient notice given 22 days after failure to appear); Classic City Bonding Co. v. State of Ga., 256 Ga. App. 577, 578 ( 568 SE2d 834 ) (2002) (sufficient notice given 12 days after failure to appear); AAA Bonding Co. v. State of Ga., 192 Ga. App. 684, 685 (2) ( 386 SE2d 50 ) (1989) (statute then required notice within 72 hours of failure to appear; notice sent five days after failure was suff

2010We have previously held that the ten-day notice requirement could be satisfied by the State’s “substantial compliance.” Northeast Atlanta Surety Co. v. Perdue, 294 Ga. App. 32 ( 668 SE2d 508 ) (2008) (sufficient notice given 22 days after failure to appear); Classic City Bonding Co. v. State of Ga., 256 Ga. App. 577, 578 ( 568 SE2d 834 ) (2002) (sufficient notice given 12 days after failure to appear); AAA Bonding Co. v. State of Ga., 192 Ga. App. 684, 685 (2) ( 386 SE2d 50 ) (1989) (statute then required notice within 72 hours of failure to appear; notice sent five days after failure was suff

12010–2010
Adams v. State green
gactapp · 1989
2 sentences

1992Adams v. State, 191 Ga. App. 16 (4) ( 381 SE2d 69 ) (1989). (b) Appellant next argues that the transaction was not sufficiently similar to the offense of which he was convicted. “ ‘Before evidence of similar offenses is admissible, two criteria must be met.

1992Adams v. State, 191 Ga. App. 16 (4) ( 381 SE2d 69 ) (1989). (b) Appellant next argues that the transaction was not sufficiently similar to the offense of which he was convicted. “ ‘Before evidence of similar offenses is admissible, two criteria must be met.

11992–1992
Darnell v. Betty's Creek Baptist Church green
ga · 1973
2 sentences

1978Darnell v. Betty’s Creek Baptist Church, 230 Ga. 461 ( 197 SE2d 714 ) (1973).

1978Darnell v. Betty’s Creek Baptist Church, 230 Ga. 461 ( 197 SE2d 714 ) (1973).

11978–1978
Dunlap v. Citizens & Southern DeKalb Bank green
gactapp · 1975
2 sentences

1977Dunlap v.C & S DeKalb Bank, 134 Ga. App. 893 (6) ( 216 SE2d 651 ).

1977Dunlap v.C & S DeKalb Bank, 134 Ga. App. 893 (6) ( 216 SE2d 651 ).

11977–1977

Statutes the citing opinions construe

GA § 10-1-36 (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

MS 12 (1917–2016) GA 11 (1977–2016) FL 7 (1961–2009) AL 6 (1984–2024) TX 5 (1977–2025) MO 4 (1994–2012) IN 4 (2003–2019) MN 4 (1987–1998) RI 3 (1983–2005) AR 2 (1993–1994) NJ 2 (1980–2002) NY 2 (2024–2024) DC 2 (2011–2022) UT 2 (2014–2025) IA 2 (1984–2020)

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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