O.C.G.A.

O.C.G.A. § 24-4-406 (2019)

Habit; routine practice

✓ O.C.G.A. — 2019 edition (Public.Resource.Org Release 73)
Code text and O.C.G.A. statutory annotations on this page reflect the 2019 Official Code of Georgia Annotated (Public.Resource.Org Release 73, 2019-08-21; public domain per Georgia v. Public.Resource.Org, 2020). The Syfert case-law annotations in Notes of Decisions, below, are current.
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Evidence of the habit of a person or of the routine practice of an organization, whether corroborated or not and regardless of the presence of eyewitnesses, is relevant to prove that the conduct of the person or organization on a particular occasion was in conformity with such habit or routine practice.

History

Code 1981, § 24-4-406, enacted by Ga. L. 2011, p. 99, § 2/HB 24.

Annotations

Cross references. Habit; routine practice, Fed. R. Evid. 406.

JUDICIAL DECISIONS Editor’s notes. - In light of the similarity of the statutory provisions, decisions under former O.C.G.A. § 24-2-2 are included in the annotations for this Code section. Habit and customs. - Witness may testify as to the witness’s fixed and uniform habit but not as to the habit and customs of another, when the actor is available to testify personally. Feinberg v. Durga, 189 Ga. App. 733, 377 S.E.2d 33, 1988 Ga. App. LEXIS 1501 (1988) (decided under former O.C.G.A. § 24-2-2). Not habit evidence. - Testimony about the defendant’s prior driving on the curve in question was not habit evidence. Evans-Glodowski v. State, 335 Ga. App. 484, 781 S.E.2d 591, 2016 Ga. App. LEXIS 11 (2016). Business’s routine practice may be admissible. - In a dispute over a storage

facility’s storage of a customer’s seed, in which the facility sought to bind the customer to limitations printed on the reverse of the facility’s warehouse receipts, the trial court erred by concluding that evidence that the facility routinely mailed warehouse receipts to the facility’s customers was sufficient to bind the customer as a matter of law; because the customer denied receiving the receipts, the customer’s assent was a question for the jury. Turfgrass Group v. Ga. Cold Storage Co., 346 Ga. App. 659, 816 S.E.2d 716, 2018 Ga. App. LEXIS 436 (2018).

Notes of Decisions
Cited in 2 cases, 2016–2018 · leading case: Evans-Glodowski v. the State, 781 S.E.2d 591 (Ga. Ct. App. 2016).
Evans-Glodowski v. the State, 781 S.E.2d 591 (Ga. Ct. App. 2016). · cites it 8× “Because this case was tried after January 1, 2013, OCGA § 24-4-406 governs the use of habit evidence.”
The Turfgrass Grp., Inc. v. Georgia Cold Storage Co., 816 S.E.2d 716 (Ga. Ct. App. 2018). · cites it 2× “While evidence of Cold Storage's routine practice might be admissible under OCGA § 24-4-406, 4 a jury must determine whether this routine practice was followed with regard to Turfgrass.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.