ATLANTA RESTAURANT PARTNERS, LLC. v. CLAYTON COUNTY

CourtCourt of Appeals of Georgia
DecidedJune 10, 2025
DocketA25A0445
StatusPublished

This text of ATLANTA RESTAURANT PARTNERS, LLC. v. CLAYTON COUNTY (ATLANTA RESTAURANT PARTNERS, LLC. v. CLAYTON COUNTY) 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
ATLANTA RESTAURANT PARTNERS, LLC. v. CLAYTON COUNTY, (Ga. Ct. App. 2025).

Opinion

FOURTH DIVISION MERCIER, C. J., DILLARD, P. J., and LAND, J.

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

June 10, 2025

In the Court of Appeals of Georgia A25A0445. ATLANTA RESTAURANT PARTNERS, LLC. v. CLAYTON COUNTY et al.

MERCIER, Chief Judge.

Atlanta Restaurant Partners, LLC (“Taxpayer”) filed an action pursuant to

OCGA § 48-5-380 for a refund of ad valorem taxes paid to Clayton County (“the

County”) and The City of College Park (“the City”).1 The Clayton County School

District (“the School District”) filed a motion to intervene. The trial court granted

the School District’s motion to intervene and, later, its motion for partial dismissal of

the Taxpayer’s claims. Following the entry of final judgment, the Taxpayer filed this

appeal of the orders granting the School District’s motions. Because the trial court

1 Taxpayer filed the action against Clayton County, Clayton County Board of Commissioners, the City of College Park, the College Park Mayor and City Council. erred in granting the School District’s motion to intervene and motion for partial

dismissal, we reverse and remand.

The complaint alleges that, in 2013, the Taxpayer entered into a contract with

the City of Atlanta to provide retail food and beverage concessions at Hartsfield-

Jackson Atlanta International Airport (“the Airport”). The City and the County

assessed and collected from the Taypayer real property ad valorem taxes relating to

the Airport concession agreement for the years 2014 and 2015.

In 2019, the Taxpayer filed the underlying OCGA § 48-5-380 action seeking to

recover $296,913.13 from the County and $48,213.03 from the City, along with

interest and attorney fees, arguing that the County and City illegally taxed the

Taxpayer’s nontaxable airport usufruct.

Pursuant to OCGA § 48-5-380,

[E]ach county and municipality shall refund to taxpayers any and all taxes and license fees:

(1) Which are determined to have been erroneously or illegally assessed and collected from the taxpayers under the laws of this state or under the resolutions or ordinances of any county or municipality; or

2 (2) Which are determined to have been voluntarily or involuntarily overpaid by the taxpayers.

OCGA § 48-5-380 (a). “Any refunds approved or allowed under this Code section

shall be paid from funds of the county, the municipality, the county board of

education, the state, or any other entity to which the taxes or license fees were

originally paid.” OCGA § 48-5-380 (d).

In 2020, the School District filed a motion to intervene in the underlying action,

arguing that it had a right to intervene because a portion of the taxes collected by the

County from the Taxpayer “became property of” the School District. The School

District argued that it “ha[d] a right to intervene due to the fact that more than half

of the money sought by [the Taxpayer] against [the County] is the property of, and has

already been remitted to [the School District].” The School District also alleged that

it was protected from the action by sovereign immunity. Sometime later, the trial

court granted the motion to intervene and sent the signed order to the Taxpayer but

failed to file the order in the record.2

2 Of note, “it shall be the duty of the judge to file his or her decision with the clerk of the court in which the cases are pending and to notify the attorney or attorneys of the losing party of his or her decision[.]” OCGA § 15-6-21 (c). 3 The City issued a tax refund to the Taxpayer in the amount of $59,604.51, and

the City and the Taxpayer submitted a proposed consent order to the trial court

dismissing the City from the action. While the trial court signed the order, it again

failed to file the order in the record.

Thereafter, the School District filed a motion for partial dismissal, arguing that

the Taxpayer’s OCGA § 48-5-380 action, into which it had intervened as a defendant,

failed to state a claim against it and the action was barred by the School District’s

sovereign immunity. The trial court agreed and granted the motion, dismissing the

Taxpayer’s claim for a refund of taxes the County had remitted to the School District.

Following the dismissal order, and prior to court-ordered mediation, the

County refunded the remaining tax amounts at issue to the Taxpayer. The trial court

signed, and filed, the order of final judgment, and this appeal followed.

1. In two separate enumerated errors, the Taxpayer contends that the trial court

erred by allowing the School District to intervene. The School District moved to

intervene as a matter of right under OCGA § 9-11-24 (a).

OCGA § 9-11-24 (a) provides pertinently that:

Upon timely application anyone shall be permitted to intervene in an action . . . [w]hen the applicant claims an interest relating to the property

4 or transaction which is the subject matter of the action and he is so situated that the disposition of the action may as a practical matter impair or impede his ability to protect that interest, unless the applicant’s interest is adequately represented by existing parties.

This “requires a three-fold showing of (1) interest, (2) potential impairment, and (3)

inadequate representation.” DeKalb County v. Post Properties, 245 Ga. 214, 219 (2)

(263 SE2d 905) (1980); accord Buckler v. DeKalb County, 290 Ga. App. 190, 193 (2)

(659 SE2d 398) (2008). We review a trial court’s grant or denial of a motion for

intervention as a matter of right for an abuse of discretion. Henry County School

District v. Home Depot U. S. A, 348 Ga. App. 723, 724 (824 SE2d 622) (2019).

It is well settled that leased retail space at the Airport to operate food

concessions are “not estates in real property, but instead [are] usufructs that [are] not

subject to ad valorem real estate taxes.” Hojeij Branded Foods, LLC v. Clayton County,

355 Ga. App. 222, 223 (843 SE2d 902) (2020); see also Clayton County Bd. of Tax

Assessors v. Aldeasa Atlanta Joint Venture, 304 Ga. 15, 16-17 (1) (815 SE2d 870) (2018).

The County and the City assessed and collected ad valorem taxes from the Taxpayer

regarding the Taxpayer’s food and beverage concessions at the Airport. The retail

spaces were usufructs and not subject to ad valorem real estate taxes. See Hojeij

5 Branded Foods, 355 Ga. App. at 223; Clayton County Bd. of Tax Assessors, 304 Ga. at 16-

17 (1). Therefore, the City and County’s assessed taxes were illegally collected from

Free access — add to your briefcase to read the full text and ask questions with AI

Related

DeKalb County v. Post Properties, Inc.
263 S.E.2d 905 (Supreme Court of Georgia, 1980)
Buckler v. DeKalb County
659 S.E.2d 398 (Court of Appeals of Georgia, 2008)
Potter's Properties, LLC v. Vns Corp.
703 S.E.2d 79 (Court of Appeals of Georgia, 2010)
HENRY COUNTY SCHOOL DISTRICT v. HOME DEPOT U. S. A., INC. Et Al.
824 S.E.2d 622 (Court of Appeals of Georgia, 2019)
Atlanta Board of Education v. City of Atlanta
413 S.E.2d 716 (Supreme Court of Georgia, 1992)
Clayton Cnty. Bd. of Tax Assessors v. Aldeasa Atlanta Joint Venture
815 S.E.2d 870 (Supreme Court of Georgia, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
ATLANTA RESTAURANT PARTNERS, LLC. v. CLAYTON COUNTY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/atlanta-restaurant-partners-llc-v-clayton-county-gactapp-2025.