ATG SPORTS INDUSTRIES, INC. v. ITS SPRINTURF HOLDINGS, LLC

CourtCourt of Appeals of Georgia
DecidedMarch 12, 2026
DocketA25A1649
StatusPublished

This text of ATG SPORTS INDUSTRIES, INC. v. ITS SPRINTURF HOLDINGS, LLC (ATG SPORTS INDUSTRIES, INC. v. ITS SPRINTURF HOLDINGS, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ATG SPORTS INDUSTRIES, INC. v. ITS SPRINTURF HOLDINGS, LLC, (Ga. Ct. App. 2026).

Opinion

FIFTH DIVISION MCFADDEN, P. J., HODGES and PIPKIN, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

March 12, 2026

In the Court of Appeals of Georgia A25A1649. ATG SPORTS INDUSTRIES, INC. et al. v. ITS SPRINTURF HOLDINGS, LLC.

MCFADDEN, Presiding Judge.

ATG Sports Industries, Inc. and ATG-RAM Industries, LLC jointly appeal

from the denial of their motions for new trial or judgment notwithstanding the jury

verdict finding that ATG-RAM was the alter ego of ATG Sports and that they were

both liable to ITS Sprinturf Holdings, LLC (“ITS”) for breach of contract. The

appellants contend that the trial court erred in denying their motions because, as two

of our opinions have stated, Georgia law has never applied the alter ego doctrine

1 We have circulated this decision amongst all nondisqualified judges of the Court to consider whether this case should be passed upon by all members of theCourt. Fewer than the required numbers of judges, however, voted in favor of considering this case en banc. horizontally between sibling companies; but a review of the case law reveals that

Georgia courts have applied the doctrine in that manner. And because there was some

evidence to support the jury’s alter ego verdict, we affirm the denial of their motions

on those grounds. But in doing so, we must disapprove the language in our two

opinions that incorrectly stated that Georgia law has not recognized the alter ego

doctrine among sibling companies.

The appellants also assert two objections to the trial court’s jury instructions;

but they failed to raise those objections below and they have not shown substantial

error in the instructions. The appellants’ additional challenge to a contract issue that

was decided on summary judgment is moot after the jury verdict and entry of

judgment thereon. And there was some evidence supporting the jury’s award of

attorney fees. So we affirm.2

1. Procedural posture

ITS filed a complaint against ATG-Sports, claiming breach of contract. The

complaint alleged that ITS manufactures and supplies artificial turf; that ATG-Sports

2 Oral argument was held in this case on October 22, 2025, and is archived on the court’s website. See Court of Appeals of Georgia, Oral Argument, Case No. A25A1649 (October 22, 2025), available at https://vimeo.com/1129972699. 2 installs and maintains artificial turf on sports fields; that ITS and ATG-Sports entered

into an agreement for ATG-Sports “to purchase substantially all of [its] turf

requirements” from ITS; and that ATG-Sports breached the agreement by

purchasing a substantial amount of its artificial turf requirements from a manufacturer

other than ITS. ITS amended the complaint to add ATG-RAM as a defendant,

claiming that it was also liable as the alter ego of ATG Sports, and to add a claim for

attorney fees under OCGA § 13-6-11. ATG-RAM filed a counterclaim alleging sale of

defective products.3

The case was tried before a jury. At the close of the plaintiff’s evidence, the trial

court denied a defense motion for directed verdict on the alter ego theory of liability.

The jury subsequently returned a verdict in favor of ITS, finding that ATG-RAM was

the alter ego of ATG Sports; that ATG Sports breached the agreement; that ITS was

entitled to $715,609 in damages, $53,860 in prejudgment interest, and $120,000 in

attorney fees and expenses; and that ITS was not liable on ATG-RAM’s counterclaim.

The trial court entered final judgment in the amounts awarded by the jury, plus post-

3 ITS points out, as it did at trial, that ATG-RAM’s counterclaim included a claim for the return of deposits that had actually been paid by ATG Sports, but it withdrew that claim during the trial. 3 judgment interest, against ATG Sports and ATG-RAM jointly and severally. ATG

Sports and ATG-RAM filed motions for a new trial and judgment notwithstanding the

verdict (“JNOV”). The trial court denied the motions, and this appeal followed.

2. Horizontal alter ego

ATG Sports and ATG-RAM contend that the trial court erred by refusing to

grant them judgment as a matter of law because Georgia has never recognized a

“horizontal alter ego” theory of liability amongst sibling companies. Although their

contention is supported by statements in two prior opinions from this court, as

explained below, those statements were incorrect and are thus disapproved.

In Cobra 4 Enters. v. Powell-Newman, 336 Ga. App. 609 (785 SE2d 556) (2016)

(physical precedent only), this court rejected an attempt to impose liability

horizontally between a company and its sibling corporation, stating that “Georgia

courts have never applied the alter ego doctrine to impose liability in this manner.”

Id. at 614 (2). But this statement was not supported by any legal authority, and “right

after this statement, Cobra 4 expressly considered whether the two entities in that case

could be [liable as] each other’s alter egos. The Cobra 4 court concluded that, on the

facts, the two corporations were not alter egos because there was no evidence that the

4 two companies were interchangeable entities.” Knieper v. Forest Group USA, No.

4:15-CV-00222-HLM, slip op. at 23 (III) (B) (6) (ND Ga. Sept. 12, 2016) (2016 U.S.

Dist. LEXIS 190287) (citations and punctuation omitted).

Although the unsupported Cobra 4 statement was non-binding physical

precedent, it was later adopted by this court in Price & Co. v. Majors Mgmt., 363 Ga.

App. 427 (869 SE2d 587) (2022). See CMGRP v. Gallant, 343 Ga. App. 91, 96 (2) (a)

n. 15 (806 SE2d 16) (2017) (the fact that an opinion is only physical precedent is of no

consequence if a subsequent, unanimous panel of this court fully adopts the opinion’s

reasoning). Price & Co. quoted and emphasized the Cobra 4 statement recited above

and then declined “to incorporate the doctrine of horizontal veil piercing into Georgia

jurisprudence and to use it to impose liability on [the sibling companies in that case].”

Id. at 438 (4).

But contrary to the statements made in Cobra 4 and Price & Co., a review of

Georgia case law demonstrates, and a Georgia federal district court has concluded,

that there is “no reason to hold that Georgia does not recognize horizontal alter ego

liability. In fact ,Georgia [courts have] repeatedly considered whether one entity is the

alter ego of another.” Knieper, supra at 19 (III) (B) (6). Accord Salas v. Statebridge Co.,

5 No. 1:21-CV-3959-SDG-JCF, slip op. at 45 (II) (E) (ND Ga. July 19, 2022) (2022 U.S.

Dist. LEXIS 180565) (rejecting contention that Georgia courts have not recognized

horizontal alter ego and veil piercing to impose liability on sibling companies). While

some of those cases, like Cobra 4 itself, have found insufficient evidence to support

such an alter ego claim under their particular facts, others have recognized that sibling

companies may be liable as alter egos of each other. See, e. g., NEC Techs. v. Nelson,

267 Ga. 390, 397 (5) (478 SE2d 769) (1996) (reversing this court’s finding of genuine

issues of material fact as to whether one company was the alter ego of another

company because there was “an absence of any evidence establishing the existence of

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ATG SPORTS INDUSTRIES, INC. v. ITS SPRINTURF HOLDINGS, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/atg-sports-industries-inc-v-its-sprinturf-holdings-llc-gactapp-2026.