City of Sandy Springs, Georgia v. City of Atlanta, Georgia

CourtCourt of Appeals of Georgia
DecidedMarch 16, 2021
DocketA20A1932
StatusPublished

This text of City of Sandy Springs, Georgia v. City of Atlanta, Georgia (City of Sandy Springs, Georgia v. City of Atlanta, Georgia) 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 Sandy Springs, Georgia v. City of Atlanta, Georgia, (Ga. Ct. App. 2021).

Opinion

FIFTH DIVISION REESE, P. J., MARKLE and COLVIN, 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

DEADLINES ARE NO LONGER TOLLED IN THIS COURT. ALL FILINGS MUST BE SUBMITTED WITHIN THE TIMES SET BY OUR COURT RULES.

February 26, 2021

In the Court of Appeals of Georgia A20A1932. CITY OF SANDY SPRINGS v. CITY OF ATLANTA.

REESE, Presiding Judge.

The City of Sandy Springs sued the City of Atlanta, alleging violations of the

Open Records Act1 and the Service Delivery Strategy (“SDS”) Act,2 and seeking

injunctive relief. The Superior Court of Fulton County dismissed Counts 2 and 3 of

the second amended complaint, which alleged violations of the SDS Act, and denied

Sandy Springs’s motion to transfer venue. Sandy Springs appeals, arguing that the

superior court erred in finding that Sandy Springs had to be a party to the current

service delivery strategy in order to use OCGA § 36-70-28 (c), that the court erred in

finding that Sandy Springs was required to engage in alternative dispute resolution

1 See OCGA § 50-18-70 et seq. 2 See OCGA § 36-70-20 et seq. before using OCGA § 36-70-24, and that the court lacked jurisdiction. For the reasons

set forth infra, we affirm.

Viewing as true all well-pleaded material allegations,3 the second amended

complaint (the “Complaint”) alleged that in October 2005, a service delivery

agreement designated the City of Atlanta as the direct retail water service provider

for all of unincorporated Fulton County, which included the area that was later

incorporated as the City of Sandy Springs in December 2005. Count 2 alleged that

Atlanta maintained an outside city water rate that was 21 percent higher than the

inside water rate, and that this rate differential was arbitrary, in violation of OCGA

§ 36-70-24 (2) (B).

Count 3 of the Complaint alleged that Atlanta’s refusal to review and revise the

water fees assessed to Sandy Springs customers violated the SDS Act, and that Sandy

Springs was entitled to alternative dispute resolution under OCGA § 36-70-28 (c),

and specifically that a judge outside the circuit initiate mandatory mediation pursuant

to OCGA § 36-70-25.1 (d) (1). Sandy Springs filed a motion to transfer venue,

3 See Atlanta Metro Leasing v. City of Atlanta, 353 Ga. App. 785, 786 (839 SE2d 278) (2020).

2 requesting transfer to an adjoining judicial circuit superior court pursuant to § 36-70-

25.1 (d) (1) (A).

The superior court granted Atlanta’s motion to dismiss Counts 2 and 3 and

denied the motion to transfer venue. The court found that Count 2 was premature

because no alternative dispute resolution had occurred, as required by OCGA § 36-

70-24 (2) (B). The court dismissed Count 3 and denied the transfer motion because

Sandy Springs admitted it was not a party to the current service delivery strategy, and

therefore could not avail itself of the procedure set forth in OCGA § 36-70-28 (c).

This appeal followed.

In considering dismissal under OCGA § 9-11-12 (b) (6) [for failure to state a claim upon which relief can be granted], the trial court must accept as true all well-pled material allegations in the complaint and must resolve any doubts in favor of the plaintiff. This court reviews a trial court’s ruling on a motion to dismiss de novo, viewing as true all well-pleaded material allegations in the complaint. However, we are under no obligation to adopt a party’s legal conclusions based on these facts.4

4 Atlanta Metro Leasing, 353 Ga. App. at 786 (citations and punctuation omitted).

3 With these guiding principles in mind, we turn now to the claims of error asserted by

Sandy Springs.

1. Sandy Springs argues that the trial court erred by holding that Sandy Springs

was required to be a party to the current service delivery strategy before it could

utilize subsection (c) of OCGA § 36-70-28 (“Section 28”). In Count 3 of the

Complaint, Sandy Springs alleged that it had requested that Atlanta review and revise

its water fees pursuant to subsections (b) (2) and (b) (3) of Section 28.5

Under subsection (c) of Section 28, “[i]n the event that a county or an affected

municipality located within the county refuses to review and revise, if necessary, a

strategy in an accordance with paragraphs (2) and (3) of subsection (b)[,] then any of

the parties may use the alternative dispute resolution and procedures set forth in

[OCGA § 36-70-25.1 (d)].” “As used in [Section 28], the term ‘affected municipality’

means each municipality required to adopt a resolution approving the local

5 Under OCGA § 36-70-28 (b) (2) and (3), “[e]ach county and affected municipality shall review, and revise if necessary, the approved strategy: [w]henever necessary to change service delivery or revenue distribution arrangements; [or w]henever necessary due to changes in revenue distribution arrangements[.]”

4 government service delivery strategy pursuant to subsection (b) of Code Section 36-

70-25.”6

Viewing as true the well-pleaded material allegations in the Complaint, Section

28 does not apply to the parties’ dispute. Sandy Springs was not incorporated until

December 2005, and thus is not an “affected municipality” as it was not required to

adopt a resolution approving the service delivery strategy because the strategy was

already in place.7

Instead, the more specific statute, OCGA § 36-70-24 (“Section 24”), regarding

water rate differentials, applies.8 That section provides in relevant part:

If a governing authority disputes the reasonableness of water and sewer rate differentials imposed within its jurisdiction by another governing authority, that disputing governing authority may hold a public hearing for the purpose of reviewing the rate differential. Following the preparation of a rate study by a qualified engineer, the governing authority may challenge the arbitrary rate differentials on behalf of its

6 OCGA § 36-70-28 (a).

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City of Sandy Springs, Georgia v. City of Atlanta, Georgia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-sandy-springs-georgia-v-city-of-atlanta-georgia-gactapp-2021.