Clint Larkin v. Madison County School District

CourtCourt of Appeals of Georgia
DecidedMay 24, 2022
DocketA22A0209
StatusPublished

This text of Clint Larkin v. Madison County School District (Clint Larkin v. Madison County School District) 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
Clint Larkin v. Madison County School District, (Ga. Ct. App. 2022).

Opinion

THIRD DIVISION DOYLE, P. J., REESE, J., and SENIOR APPELLATE JUDGE PHIPPS

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

May 24, 2022

In the Court of Appeals of Georgia A22A0209. LARKIN v. MADISON COUNTY SCHOOL DISTRICT.

REESE, Judge.

Clint Larkin seeks review of an order of the Superior Court of Madison

County, which denied his motion to enjoin the attempts of Madison County School

District (the “District”) to collect on a purported “judgment” against Larkin. For the

reasons set forth infra, we reverse the denial of injunctive relief and remand for

further proceedings.

All Steel Construction, Inc., sued the District and Larkin in 2016, alleging that

Larkin had contracted with the District to construct a new wrestling building at a high

school sports complex, that the District had failed to require Larkin to post a payment

bond as required by OCGA § 36-91-90, and that both defendants were thus liable for Larkin’s failure to pay All Steel for steel building materials it had furnished to Larkin.

The District filed an answer and cross-claim against Larkin, alleging that it had paid

Larkin the total sum for construction of the building and that, upon information and

belief, Larkin had failed to pay All Steel for the materials.

Thereafter, All Steel filed a “Voluntary Dismissal with Prejudice as to

Defendant Madison County School District Only,” emphasizing that it was dismissing

the District “only” from the action and that “Larkin shall ‘not’ be dismissed.”

The District next filed a motion for default judgment against Larkin along with

a copy of a “Release” in which All Steel had assigned all of its rights in the action to

the District, including all claims All Steel had against Larkin. The trial court entered

an order of default judgment against Larkin in February 2017, finding that Larkin was

in default and that he had raised no defense as to the complaint or the cross-claim.

More than two years later, the trial court held a hearing on damages. The record

on appeal does not contain a transcript of this hearing. The trial court entered an

“Order” on June 21, 2019 (the “2019 Order”), finding:

This matter came before the Court on June 5, 2019 on [the District’s] Motion for Damages against [Larkin]. At the hearing, these Parties agreed to the following terms:

2 [Larkin] is liable for damages of $110,000 to [the District]. He will pay the [District] $25,000 of that amount by July 1, 2019. He will pay the remaining balance of $85,000 by October 1, 2019. Upon that payment, [the District] will notify the Court and this matter, including [the District’s] Cross Claim against [Larkin], will be dismissed.

The court noted: “[All Steel] previously filed a dismissal of its claims against the

[District], pursuant to a settlement with the [District]. As part of that settlement [All

Steel] assigned its claims against [Larkin] to [the District].”

In January 2021, Larkin, having apparently retained counsel, filed a “Motion

to Vacate and Set Aside Purported ‘Judgment’ and Enjoin Execution and Collection.”

Larkin attached to the motion, inter alia, a writ of fieri facias recorded in superior

court, an affidavit of garnishment, and notices to take a post-judgment deposition of

Larkin. The District responded and filed a motion for contempt and sanctions based

in part on Larkin’s failure to appear at the rescheduled deposition.

Following a hearing, the trial court denied Larkin’s motion. The court found:

(1) the 2019 Order was a final judgment upon which collection could be based, and

the 2019 Order related back to the 2017 order of default judgment; (2) the lack of a

civil case disposition form did not render the “judgment” ineffective; (3) Larkin failed

to timely file his motion to vacate and set aside the judgment because it was not filed

3 within three years of the default judgment; and (4) the District remained a party to the

action, and thus could file its motion for default judgment and subsequent motions

seeking payment.

We granted Larkin’s application for discretionary appeal. In our order, we

stated that “it appears that this case remains pending before the trial court[ ]” based

on the plain terms of the 2019 Order. We noted that generally a party had to comply

with the interlocutory appeal requirements, which included obtaining a certificate of

immediate review from the trial court. Because the trial court also denied Larkin’s

motion for interlocutory injunctive relief, which was directly appealable, we granted

Larkin’s application. This appeal followed.

As a general rule, a trial court has broad discretion in deciding whether to grant or deny an interlocutory injunction, and this Court will not disturb the trial court’s decision absent manifest abuse of discretion. Further, where the trial court, in ruling on an interlocutory injunction, makes findings of fact based upon conflicting evidence, this court will not disturb the ruling as an abuse of discretion unless the denial or granting of the injunction was based on an erroneous interpretation of the law.1

1 Westpark Walk Owners v. Stewart Holdings, 288 Ga. App. 633, 635 (655 SE2d 254) (2007) (citations and punctuation omitted).

4 With these guiding principles in mind, we turn now to Larkin’s claims of error.

1. Larkin argues that the trial court erred in denying his motion to set aside the

2019 Order and enjoin its enforcement because the District’s conditional claims

against him for indemnity were mooted and dismissed by operation of law when All

Steel dismissed and released the District.

(a) As an initial matter, we reject the District’s argument in response that our

order granting Larkin’s application for discretionary review renders the rest of his

appeal moot. Specifically, the District argues that because Larkin sought a ruling that

the 2019 Order was not final, and because we already ruled that the order was not a

final judgment (by finding that the case appeared to remain pending in the trial court),

his motion for injunctive relief is moot.

Our statement that the case “appear[ed]” to remain pending was made in the

context of whether Larkin needed to comply with the interlocutory appeal

requirements of OCGA § 5-6-34 (b) and did not constitute a ruling on the merits of

Larkin’s appeal.2 Moreover, the denial of Larkin’s request for injunctive relief is not

2 Compare Court of Appeals Rule 30 (b) (interlocutory applications), with Court of Appeals Rule 31 (b) (discretionary applications); cf. Guthrie v. Wickes, 295 Ga. App. 892, 894 (2) (673 SE2d 523) (2009) (“An order denying an application for discretionary review invokes the doctrine of res judicata when . . . the judgment appealed from is final and on the merits.”).

5 moot because the thing sought to be enjoined (the District’s collection of the entire

amount it contends it is owed) has not occurred.3 The District’s reliance on our

decision in Jenkins v. Smith4 is misplaced.

(b) We turn now to the merits of Larkin’s argument that the notice of voluntary

dismissal mooted and dismissed the District’s conditional claims against him for

indemnity.

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Related

Westpark Walk Owners, LLC v. Stewart Holdings, LLC
655 S.E.2d 254 (Court of Appeals of Georgia, 2007)
Alexander Underwriters, Inc. v. Insurance Agencies of Georgia, Inc.
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Wilmington Trust Co. v. Glynn County
595 S.E.2d 562 (Court of Appeals of Georgia, 2004)
Georgia Power Co. v. Franco Remodeling Co.
525 S.E.2d 152 (Court of Appeals of Georgia, 1999)
Guthrie v. Wickes
673 S.E.2d 523 (Court of Appeals of Georgia, 2009)
Thomas v. Auto Owners Insurance
472 S.E.2d 707 (Court of Appeals of Georgia, 1996)
Metropolitan Atlanta Rapid Transit Authority v. Federick
371 S.E.2d 204 (Court of Appeals of Georgia, 1988)
Smith v. United Insurance Co. of America
315 S.E.2d 265 (Court of Appeals of Georgia, 1984)
Zeitman v. McBrayer
412 S.E.2d 287 (Court of Appeals of Georgia, 1991)
Jenkins v. Smith
709 S.E.2d 23 (Court of Appeals of Georgia, 2011)
James Giles v. State Farm Mutual Insurance
765 S.E.2d 413 (Court of Appeals of Georgia, 2014)
Atkinson v. Railroad Employes Mutual Relief Society
22 S.W.2d 631 (Tennessee Supreme Court, 1929)
Flemister v. Hopko
495 S.E.2d 342 (Court of Appeals of Georgia, 1998)
Pazur v. Belcher
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Bluebook (online)
Clint Larkin v. Madison County School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/clint-larkin-v-madison-county-school-district-gactapp-2022.