- Court
- Supreme Court of Georgia
- Year
- 2024
- Case
- Williams v. Regency Hospital Company, LLC
- Citation
- 318 Ga. 145
- Decided
- January 17, 2024
The Supreme Court of Georgia lacks exclusive jurisdiction over a constitutional challenge when the trial court does not distinctly rule on a novel constitutional question but instead relies on existing precedent to resolve the issue.
Summary
On January 17, 2024, the Supreme Court of Georgia issued an order in Williams v. Regency Hospital Company, LLC, 318 Ga. 145, transferring a medical-malpractice appeal to the Court of Appeals. The case involved a challenge to the constitutionality of OCGA § 9-3-73 (b), which prevents the tolling of the statute of limitations for mentally incompetent plaintiffs in medical-malpractice cases. The trial court granted the defendants’ motions to dismiss based on the statute of limitations, and the Supreme Court held that because the trial court did not distinctly rule on a novel constitutional issue, the Supreme Court lacked exclusive jurisdiction.
Issues Decided
Exclusive Appellate Jurisdiction over Constitutional Challenges
Decision
The Supreme Court of Georgia decided it did not have exclusive jurisdiction over the appeal because the trial court failed to distinctly rule on a novel constitutional question.
Facts
In April 2023, Andreana Williams filed a medical-malpractice action on behalf of a mentally incapacitated ward for treatment received in late 2020. The defendants moved to dismiss, arguing the two-year statute of limitations in OCGA § 9-3-71 (a) barred the claims because OCGA § 9-3-73 (b) subjects mentally incompetent persons to the standard medical-malpractice limitation periods without the benefit of tolling. Williams argued that OCGA § 9-3-73 (b) violated the Equal Protection Clause of the Fourteenth Amendment by treating mentally incompetent medical-malpractice plaintiffs differently than mentally incompetent plaintiffs in other types of cases. The trial court granted the motions to dismiss, stating that the Supreme Court had already decided the issue against the plaintiff in Deen v. Stevens, 287 Ga. 597 (2010).
Reasoning
The Supreme Court’s exclusive jurisdiction is triggered only when a constitutional question is raised and “distinctly ruled upon” in the trial court. In this case, the trial court concluded that Williams’s arguments were foreclosed by the existing precedent in Deen. Because the trial court did not address the arguments to the extent they might have raised an issue distinct from Deen, it did not provide the specific ruling necessary to invoke the Supreme Court’s exclusive jurisdiction. The Court noted that if the Court of Appeals disagrees with the trial court’s reliance on Deen, it may vacate the order and remand for the trial court to consider any novel constitutional questions in the first instance.
Commentary
For medical-malpractice plaintiffs challenging OCGA § 9-3-73 (b), this transfer decision illustrates a critical procedural trap at the trial-court stage. The Supreme Court’s holding turns on whether the trial court “distinctly ruled upon” a novel constitutional question. Here, the trial court’s bare citation to Deen v. Stevens without addressing whether Williams’s equal-protection arguments presented a factually or legally distinct challenge was fatal to Supreme Court jurisdiction. Plaintiff lawyers must ensure that trial courts engage substantively with novel constitutional arguments—not merely cite prior precedent—if Supreme Court review is to remain available. A trial court that summarily dismisses a constitutional claim as foreclosed by existing law may inadvertently transfer the case to the Court of Appeals, where the standard of review and procedural posture differ materially. The opinion does preserve a path forward: if the Court of Appeals disagrees with the trial court’s reliance on Deen, it may remand for the trial court to consider novel constitutional questions in the first instance. However, this procedural detour delays resolution and requires the plaintiff to persuade an intermediate appellate court before the constitutional question receives full trial-court development.
