sweeping rule in Georgia

2012See generally Lewis v. State, 312 Ga. App. 275, 280-81 (1) ( 718 SE2d 112 ) (2011) (Blackwell, J.) (providing an in-depth discussion concerning conflicts of interest). 34 To the extent that Rule 1.10 can be read to endorse such a sweeping rule, see Menton, supra note 29, at 113 (questioning the realistic ability to quarantine in-house counsel in light of Rule 1.10), we reject such an interpretation/application of the rule in the context of in-house counsel for law firms because adopting same would lead to patently absurd results, as discussed infra, and this Court “may construe statutes [and t

2012See generally Lewis v. State, 312 Ga. App. 275, 280-81 (1) ( 718 SE2d 112 ) (2011) (Blackwell, J.) (providing an in-depth discussion concerning conflicts of interest). 34 To the extent that Rule 1.10 can be read to endorse such a sweeping rule, see Menton, supra note 29, at 113 (questioning the realistic ability to quarantine in-house counsel in light of Rule 1.10), we reject such an interpretation/application of the rule in the context of in-house counsel for law firms because adopting same would lead to patently absurd results, as discussed infra, and this Court “may construe statutes [and t

2012To the extent that Rule 1.10 can be read to endorse such a sweeping rule, see Menton, supra note 29, at 113 (questioning the realistic ability to quarantine in-house counsel in light of Rule 1.10), we reject such an interpretation/application of the rule in the context of in-house counsel for law firms because adopting same would lead to patently absurd results, as discussed infra, and this Court “may construe statutes [and the like] to avoid absurd results.” State v. Mussman, 289 Ga. 586, 589 (1) ( 713 SE2d 822 ) (2011) (punctuation omitted).

2012To the extent that Rule 1.10 can be read to endorse such a sweeping rule, see Menton, supra note 29, at 113 (questioning the realistic ability to quarantine in-house counsel in light of Rule 1.10), we reject such an interpretation/application of the rule in the context of in-house counsel for law firms because adopting same would lead to patently absurd results, as discussed infra, and this Court “may construe statutes [and the like] to avoid absurd results.” State v. Mussman, 289 Ga. 586, 589 (1) ( 713 SE2d 822 ) (2011) (punctuation omitted).

2026See Abba Gana, 251 Ga. at 343 (1) (“[E]ach case has its own practicalities and peculiarities, and this [C]ourt cannot lay down a sweeping rule 4 A divorce proceeding can be either in rem or in personam, but “the distinction between in rem and in personam divorce proceedings ... is inapposite in determining if a party may resort to notice by publication. ... [R]egardless of whether a proceeding is in rem or in personam, due process requires that a chosen method of service be reasonably certain to give actual notice of the pendency of a proceeding to those parties whose liberty or property inter

2026See Abba Gana, 251 Ga. at 343 (1) (“[E]ach case has its own practicalities and peculiarities, and this [C]ourt cannot lay down a sweeping rule 4 A divorce proceeding can be either in rem or in personam, but “the distinction between in rem and in personam divorce proceedings ... is inapposite in determining if a party may resort to notice by publication. ... [R]egardless of whether a proceeding is in rem or in personam, due process requires that a chosen method of service be reasonably certain to give actual notice of the pendency of a proceeding to those parties whose liberty or property inter

2012See generally Lewis v. State, 312 Ga. App. 275, 280-81 (1) ( 718 SE2d 112 ) (2011) (Blackwell, J.) (providing an in-depth discussion concerning conflicts of interest). 34 To the extent that Rule 1.10 can be read to endorse such a sweeping rule, see Menton, supra note 29, at 113 (questioning the realistic ability to quarantine in-house counsel in light of Rule 1.10), we reject such an interpretation/application of the rule in the context of in-house counsel for law firms because adopting same would lead to patently absurd results, as discussed infra, and this Court “may construe statutes [and t

2012See generally Lewis v. State, 312 Ga. App. 275, 280-81 (1) ( 718 SE2d 112 ) (2011) (Blackwell, J.) (providing an in-depth discussion concerning conflicts of interest). 34 To the extent that Rule 1.10 can be read to endorse such a sweeping rule, see Menton, supra note 29, at 113 (questioning the realistic ability to quarantine in-house counsel in light of Rule 1.10), we reject such an interpretation/application of the rule in the context of in-house counsel for law firms because adopting same would lead to patently absurd results, as discussed infra, and this Court “may construe statutes [and t

2018Floyd , supra, 251 Ga. App. at 805 (1), 555 S.E.2d 170 ; see also Abba Gana , supra, 251 Ga. at 343 (1), 304 S.E.2d 909 ("each case has its own practicalities and peculiarities, and this court cannot lay down a sweeping rule applicable to all determinations whether reasonable diligence has been exercised").

2018Floyd , supra, 251 Ga. App. at 805 (1), 555 S.E.2d 170 ; see also Abba Gana , supra, 251 Ga. at 343 (1), 304 S.E.2d 909 ("each case has its own practicalities and peculiarities, and this court cannot lay down a sweeping rule applicable to all determinations whether reasonable diligence has been exercised").

2006Co., 149 N.H. 656, 660 ( 826 A2d 577 ) (2003) (Chevron test will no longer be applied because to permit the substantive law to shift and spring according to particular equities of parties’ claims of actual reliance on old rule and of harm from retroactive application compromises the value the court places upon stability in legal rules; furthermore, selective prospectivity of new rules only compounds the challenge to the stabilizing purpose of precedent posed by the development of the “new” rule); City of New Bern v. New Bern-Craven County Bd. of Ed., 338 N.C. 430, 442-443 ( 450 SE2d 735 ) (199

2006Co., 149 N.H. 656, 660 ( 826 A2d 577 ) (2003) (Chevron test will no longer be applied because to permit the substantive law to shift and spring according to particular equities of parties’ claims of actual reliance on old rule and of harm from retroactive application compromises the value the court places upon stability in legal rules; furthermore, selective prospectivity of new rules only compounds the challenge to the stabilizing purpose of precedent posed by the development of the “new” rule); City of New Bern v. New Bern-Craven County Bd. of Ed., 338 N.C. 430, 442-443 ( 450 SE2d 735 ) (199

2006Co., 325 Mont. 207, 217 ( 104 P3d 483 ) (2004) (Chevron test still viable as an exception to the rule of retroactivity, but exception will only be invoked when all three Chevron factors are satisfied); Christy v. Cranberry Volunteer Ambulance Corps, 579 Pa. 404, 418-419 ( 856 A2d 43 ) (2004) (while Harper decision caused Chevron Oil to lose its hold as the dominant approach for retroactive application of new decisions in current civil cases, it strengthens the general principle that changes in law are to be applied retroactively to pending cases; however, retroactive application is a matter of

2006Co., 325 Mont. 207, 217 ( 104 P3d 483 ) (2004) (Chevron test still viable as an exception to the rule of retroactivity, but exception will only be invoked when all three Chevron factors are satisfied); Christy v. Cranberry Volunteer Ambulance Corps, 579 Pa. 404, 418-419 ( 856 A2d 43 ) (2004) (while Harper decision caused Chevron Oil to lose its hold as the dominant approach for retroactive application of new decisions in current civil cases, it strengthens the general principle that changes in law are to be applied retroactively to pending cases; however, retroactive application is a matter of

2006Co., 149 N.H. 656, 660 ( 826 A2d 577 ) (2003) (Chevron test will no longer be applied because to permit the substantive law to shift and spring according to particular equities of parties’ claims of actual reliance on old rule and of harm from retroactive application compromises the value the court places upon stability in legal rules; furthermore, selective prospectivity of new rules only compounds the challenge to the stabilizing purpose of precedent posed by the development of the “new” rule); City of New Bern v. New Bern-Craven County Bd. of Ed., 338 N.C. 430, 442-443 ( 450 SE2d 735 ) (199

2006Co., 325 Mont. 207, 217 ( 104 P3d 483 ) (2004) (Chevron test still viable as an exception to the rule of retroactivity, but exception will only be invoked when all three Chevron factors are satisfied); Christy v. Cranberry Volunteer Ambulance Corps, 579 Pa. 404, 418-419 ( 856 A2d 43 ) (2004) (while Harper decision caused Chevron Oil to lose its hold as the dominant approach for retroactive application of new decisions in current civil cases, it strengthens the general principle that changes in law are to be applied retroactively to pending cases; however, retroactive application is a matter of

2006Co., 325 Mont. 207, 217 ( 104 P3d 483 ) (2004) (Chevron test still viable as an exception to the rule of retroactivity, but exception will only be invoked when all three Chevron factors are satisfied); Christy v. Cranberry Volunteer Ambulance Corps, 579 Pa. 404, 418-419 ( 856 A2d 43 ) (2004) (while Harper decision caused Chevron Oil to lose its hold as the dominant approach for retroactive application of new decisions in current civil cases, it strengthens the general principle that changes in law are to be applied retroactively to pending cases; however, retroactive application is a matter of

2006Co., 149 N.H. 656, 660 ( 826 A2d 577 ) (2003) (Chevron test will no longer be applied because to permit the substantive law to shift and spring according to particular equities of parties’ claims of actual reliance on old rule and of harm from retroactive application compromises the value the court places upon stability in legal rules; furthermore, selective prospectivity of new rules only compounds the challenge to the stabilizing purpose of precedent posed by the development of the “new” rule); City of New Bern v. New Bern-Craven County Bd. of Ed., 338 N.C. 430, 442-443 ( 450 SE2d 735 ) (199

2006Co., 149 N.H. 656, 660 ( 826 A2d 577 ) (2003) (Chevron test will no longer be applied because to permit the substantive law to shift and spring according to particular equities of parties’ claims of actual reliance on old rule and of harm from retroactive application compromises the value the court places upon stability in legal rules; furthermore, selective prospectivity of new rules only compounds the challenge to the stabilizing purpose of precedent posed by the development of the “new” rule); City of New Bern v. New Bern-Craven County Bd. of Ed., 338 N.C. 430, 442-443 ( 450 SE2d 735 ) (199

2006Co., 149 N.H. 656, 660 ( 826 A2d 577 ) (2003) (Chevron test will no longer be applied because to permit the substantive law to shift and spring according to particular equities of parties’ claims of actual reliance on old rule and of harm from retroactive application compromises the value the court places upon stability in legal rules; furthermore, selective prospectivity of new rules only compounds the challenge to the stabilizing purpose of precedent posed by the development of the “new” rule); City of New Bern v. New Bern-Craven County Bd. of Ed., 338 N.C. 430, 442-443 ( 450 SE2d 735 ) (199

2006Co., 149 N.H. 656, 660 ( 826 A2d 577 ) (2003) (Chevron test will no longer be applied because to permit the substantive law to shift and spring according to particular equities of parties’ claims of actual reliance on old rule and of harm from retroactive application compromises the value the court places upon stability in legal rules; furthermore, selective prospectivity of new rules only compounds the challenge to the stabilizing purpose of precedent posed by the development of the “new” rule); City of New Bern v. New Bern-Craven County Bd. of Ed., 338 N.C. 430, 442-443 ( 450 SE2d 735 ) (199