O.C.G.A.

O.C.G.A. § 44-7-33 (2019)

Lists of existing defects and of damages during tenancy; right of tenant to inspect and dissent; action to recover security deposit

✓ 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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(a) Prior to tendering a security deposit, the tenant shall be presented with a comprehensive list of any existing damage to the premises, which list shall be for the tenant’s permanent retention. The tenant shall have the right to inspect the premises to ascertain the accuracy of the list prior to taking occupancy. The landlord and the tenant shall sign the list and this shall be conclusive evidence of the accuracy of the list but shall not be conclusive as to latent defects. If the tenant refuses to sign the list, the tenant shall state specifically in writing the items on the list to which he dissents and shall sign such statement of dissent. (b) Within three business days after the date of the termination of occupancy, the landlord or his agent shall inspect the premises and compile a comprehensive list of any damage done to the premises which is the basis for any charge against the security deposit and the estimated dollar value of such damage. The tenant shall have the right to inspect the premises within five business days after the termination of the occupancy in order to ascertain the accuracy of the list. The landlord and the tenant shall sign the list, and this shall be conclusive evidence of the accuracy of the list. If the tenant refuses to sign the list, he shall state specifically in writing the items on the list to which he dissents and shall sign such statement of dissent. If the tenant terminates occupancy without notifying the landlord, the landlord may make a final inspection within a reasonable time after discovering the termination of occupancy. (c) A tenant who disputes the accuracy of the final damage list given pursuant to subsection (b) of this Code section may bring an action in any court of competent jurisdiction in this state to recover the portion of the security deposit which the tenant believes to be wrongfully withheld for damages to the premises. The tenant’s claims shall be limited to those items to which the tenant specifically dissented in accordance with this Code

section. If the tenant fails to sign a list or to dissent specifically in accordance with this Code section, the tenant shall not be entitled to recover the security deposit or any other damages under Code Section 44-7-35, provided that the lists required under this Code section contain written notice of the tenant’s duty to sign or to dissent to the list.

History

(Code 1933, § 61-604, enacted by Ga. L. 1976, p. 1372, § 6.)

Annotations

Law reviews. - For survey article on real property law for the period from June 1,

2002 to May 31, 2003, see 55 Mercer L. Rev. 397 (2003).

JUDICIAL DECISIONS Withholding security deposit not barred by noncompliance with security deposit provisions. - Even though a landlord did not comply with the provisions of the security deposit statute, this did not bar the landlord from bringing an action to recover unpaid rent due on a lease contract or for withholding the security deposit for nonpayment of rent. Zakaria v. McElwaney, 174 Ga. App. 149, 329 S.E.2d 310 (1985). Retention prerequisite for written statements. - When the plaintiffs did not retain the defendant’s security deposit to cover damages caused by a fire, they were never obligated to provide her with any of the written statements listed in the statute. Travelers Ins. Co. v. Linn, 235 Ga. App. 641, 510 S.E.2d 139 (1998). No forfeiture when written statements not required. - When a landlord does not retain a security deposit and is therefore not required to provide written statements un-

der O.C.G.A. §§ 44-7-33 and 44-7-34, the landlord’s failure to do so cannot work a forfeiture of the right to sue the tenant for damages to the property under O.C.G.A. § 44-7-35(b). Travelers Ins. Co. v. Linn, 235 Ga. App. 641, 510 S.E.2d 139 (1998). Inspection upon surrender. - Landlord was entitled to retain tenant’s security deposit for damages that were not normal wear and tear in the apartment the tenant rented from the landlord pursuant to a lease agreement as the landlord fulfilled the obligation of inspecting the apartment within three days of the date the tenant surrendered the apartment and thereafter notified the tenant of the balance due to repair damage that was not part of normal wear and tear. Cannon v. Wesley Plantation Apts., 256 Ga. App. 244, 568 S.E.2d 137 (2002). Cited in Kimber v. Towne Hills Dev. Co., 156 Ga. App. 401, 274 S.E.2d 620 (1980).

RESEARCH REFERENCES Am. Jur. 2d. - 49 Am. Jur. 2d, Landlord and Tenant, § 523.

C.J.S. - 52A C.J.S., Landlord and Tenant, § 989 et seq.

Notes of Decisions
Cited in 6 cases (1 in the last 5 years), 1985–2025 · leading case: AEGIS Elec. & Gas Int'l Servs. Ltd. v. ECI Mgmt. LLC, 967 F.3d 1216 (11th Cir. 2020).
AEGIS Elec. & Gas Int'l Servs. Ltd. v. ECI Mgmt. LLC, 967 F.3d 1216 (11th Cir. 2020). · cites it 3× “; (b) A damages award for [Roberson] and each Class Member in the amount of three times the unlawfully withheld security deposit pursuant to O.C.G.A. §§ 44-7-33 and 44-7-35; 33(b)(1).”
Cannon v. Wesley Plantation Apts., 568 S.E.2d 137 (Ga. Ct. App. 2002). · cites it 4× “In May 2000, Cannon sued Wesley Plantation, 1 alleging that the complex had “wilfully breached [his] contractual rights,” “wilfully failed and refused to return [his] security deposit” in violation of OCGA §§ 44-7-33, 44-7-34, and 44-7-35, and “fraudulently demanded [that he]…”
Travelers Ins. v. Linn, 510 S.E.2d 139 (Ga. Ct. App. 1998). · cites it 9× “OCGA § 44-7-33 (b) provides that “[w]ithin three business days after the date of the termination of occupancy, the landlord or his agent shall inspect the premises and compile a comprehensive list of any damage done to the premises which is the basis for any charge against the…”
Zakaria v. McElwaney, 329 S.E.2d 310 (Ga. Ct. App. 1985). · cites it 2× “The defendants also failed to comply with OCGA § 44-7-33, requiring them to provide the plaintiff with an initial and a final damage checklist.”
Sheely v. Warner Robins Hous. Auth. (M.D. Ga. 2025). · cites it 6× “§ 1983 and O.C.G.A. § 44-7-33, breached housing standards under 24 C.”
State Farm Fire & Cas. Co. v. Bajalia, 456 S.E.2d 77 (Ga. Ct. App. 1995). · cites it 14× “In violation of OCGA § 44-7-33, Canup failed to present Bajalia with a list of damages to the home prior to the time he moved in, tendered his $300 security deposit to her, or at any time thereafter.”
— 44-7-33(b) — 1 case
Sheely v. Warner Robins Hous. Auth. (M.D. Ga. 2025). “§ 1983 and O.C.G.A. § 44-7-33, breached housing standards under 24 C.”
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.