CITY OF ATLANTA v. BLOCK, INC. OF DELAWARE

CourtCourt of Appeals of Georgia
DecidedJune 17, 2025
DocketA25A0120
StatusPublished

This text of CITY OF ATLANTA v. BLOCK, INC. OF DELAWARE (CITY OF ATLANTA v. BLOCK, INC. OF DELAWARE) 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
CITY OF ATLANTA v. BLOCK, INC. OF DELAWARE, (Ga. Ct. App. 2025).

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

June 17, 2025

In the Court of Appeals of Georgia A25A0120. CITY OF ATLANTA et al. v. BLOCK, INC. OF DELAWARE.

HODGES, Judge.

Block, Inc., a company whose businesses include the payment systems Square

and CashApp, sued the City of Atlanta (the “City”), its mayor, its chief financial

officer,1 and the Atlanta City Council, seeking a partial refund of the business

occupation taxes it had paid for tax years 2016, 2017, and 2018, and arguing that the

amount of taxes was wrongly calculated. Block then moved for summary judgment,

while the City moved to dismiss Block’s complaint, arguing that the trial court lacked

jurisdiction because of sovereign immunity. In a combined order, the trial court

granted Block’s motion for summary judgment and denied the City’s motion to

1 Block later voluntarily dismissed the chief financial officer from the suit. dismiss. The City appealed. For the reasons that follow, we conclude that the trial

court had jurisdiction to consider the issues presented, and we affirm the grant of

summary judgment to Block.

The record shows that for the tax years 2016-2018, Block generated more than

$235 million in gross receipts from Georgia customers. Following an audit, in 2019,

the City assessed an additional occupation tax of nearly $330,000 on those receipts.

In 2022, Block paid approximately $540,000 — the tax, plus penalties and interest —

under protest.

Block filed the present lawsuit, which it later amended, seeking a partial tax

refund pursuant to OCGA § 48-5-380, which provides that a municipality must refund

to taxpayers any taxes that were collected erroneously or illegally. Block contends that

because it operated multiple out-of-state locations2 that contributed to its gross

revenue in Georgia in the years at issue,3 pursuant to a State statute that provides

2 Block had multiple offices during the time in question. It had 15, 20, and 28 offices in the United States in tax years 2016, 2017, and 2018, respectively, including a single Georgia office at all relevant times. 3 Block’s director of income tax compliance, David Thai, stated in a sworn affidavit that “Block had many locations or offices in the United States during the [y]ears at [i]ssue. Each of these offices contributed to Block’s business and its generation of revenue.” Thai also averred that “[n]o revenue was generated directly 2 mathematical tax calculation methods (OCGA § 48-13-14) and a similar local

ordinance (Atlanta Code § 30-80), the taxable gross receipts should be allocated on

a percentage basis, with the total number of offices, including out-of-state locations

contributing to Georgia revenue, used as the divisor and the Georgia gross receipts as

the dividend.4 Block then moved for summary judgment, arguing, inter alia, that its

Georgia gross receipts should be divided among all of its locations nationwide that

contributed to the generation of those receipts. The trial court held a hearing, but two

days later, before the court ruled, the City moved to dismiss, arguing that the court

lacked jurisdiction due to sovereign immunity because Block sought declaratory relief

but failed to satisfy the “exclusivity” requirement of Ga. Const. of 1983, Art. I, Sec.

II, Para. V (b) (2).

from the Atlanta office. The Atlanta office did not contribute to Block’s receipts from Georgia customers in any measurable way more than Block’s offices outside of Georgia did.” 4 As the trial court aptly put it, “in a world of easy math — if Block reported a total of $1,000 in gross receipts to local governments in Georgia and a network of five locations around the country contributed to generating those receipts, the City would be able to levy an occupation tax on $200 in gross receipts ($1,000 [divided by] 5 locations = $200 per location).” 3 The trial court denied the City’s motion to dismiss and granted Block’s motion

for summary judgment. In denying the motion to dismiss, the court found that Block

was not seeking declaratory relief, but rather was simply claiming a tax refund. In

granting Block’s motion for summary judgment, the court found that Block’s gross

receipts generated in Georgia could not be reasonably allocated among its offices

nationwide, and that Block’s occupation tax should be calculated based on its Georgia

gross receipts divided by the number of Block offices nationwide pursuant to OCGA

§ 48-13-14 (a) (2) in each tax year, rather than divided by Block’s sole Georgia office.

The parties do not dispute that OCGA § 48-13-14 (a) (2) applies, nor do they dispute

the amount of Block’s gross receipts in Georgia. Based on this methodology, the trial

court ordered that nearly $520,000 plus interest be refunded to Block, finding that the

total additional occupation tax Block actually owed was just more than $20,100. The

City appealed.

1. The City first contends that the trial court should have dismissed Block’s

lawsuit for lack of jurisdiction on sovereign immunity grounds because Block was

seeking declaratory relief and failed to satisfy the “exclusivity” requirement of Ga.

4 Const. of 1983, Art. I, Sec. II, Para. V (b) (2), which provides that only a municipality

may be sued in this context. We find no error.

Sovereign immunity is jurisdictional. Sons of Confederate Veterans v. Newton

County Bd. of Commrs., 368 Ga. App. 511, 512-513 (890 SE2d 468) (2023). Lawsuits

brought against a city which are barred by sovereign immunity are subject to OCGA

§ 9-11-12 (b) (1) dismissal for lack of subject-matter jurisdiction. See Sons of

Confederate Veterans, 368 Ga. App. at 513; Ga. Const. of 1983, Art. IX, Sec. II, Para.

IX (authorizing waiver of sovereign immunity for municipalities).

“We review a trial court’s ruling on a motion to dismiss based on sovereign

immunity de novo because it is a matter of law. Of course, the trial court’s factual

findings will be sustained if there is evidence to support them, and the party seeking

the waiver of immunity has the burden of proof.” (Citations omitted.) Gwinnett

County v. Ashby, 354 Ga. App. 863, 864 (842 SE2d 70) (2020).

The Georgia Constitution expressly waives sovereign immunity “for actions in

the superior court seeking declaratory relief from acts of [a] . . . municipality of this

state. . . .” Ga. Const. of 1983, Art. I, Sec. II, Para. V (b) (1). It also provides, however,

that actions against a municipality “shall be brought exclusively against such . . .

5 municipality and in the name of such . . . municipality. Actions filed pursuant to this

Paragraph naming as a defendant any individual, officer, or entity other than as

expressly authorized under this Paragraph shall be dismissed.” Ga. Const. of 1983,

Art. I, Sec. II, Para. V (b) (2).

As noted above, Block’s amended complaint named the City, the Atlanta City

Council, and the Atlanta mayor as party defendants. As a result, the City argues that

the complaint must be dismissed.

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