COWEN v. CLAYTON COUNTY

306 Ga. 698
CourtSupreme Court of Georgia
DecidedSeptember 3, 2019
DocketS19A0784
StatusPublished
Cited by1 cases

This text of 306 Ga. 698 (COWEN v. CLAYTON COUNTY) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
COWEN v. CLAYTON COUNTY, 306 Ga. 698 (Ga. 2019).

Opinion

306 Ga. 698 FINAL COPY

S19A0784. COWEN v. CLAYTON COUNTY et al.

MELTON, Chief Justice.

Linda S. Cowen, a Clayton County State Court judge since

December 1995, filed a petition for a writ of mandamus, in which

she sought, among other things, over $120,000 in back pay from

Clayton County and several of its county commissioners1 for

allegedly violating Ga. Const. of 1983, Art. VI, Sec. VII, Par. V (“All

judges shall receive compensation and allowances as provided by

law. . . . An incumbent’s salary, allowance, or supplement shall not

be decreased during the incumbent’s term of office.”). More

specifically, Cowen claimed that the County had been improperly

calculating her compensation under County Ordinance 30-4 (the

“Supplemental Ordinance”) and Local Law 2006 Ga. Laws 926 (Ga.

1 For ease of reference, Clayton County and the commissioners will hereinafter be referred to collectively as “Clayton County” or the “County.” L. 2006, p. 4654) passed by the General Assembly (the “Local Law”),2

which, she alleged, resulted in an illegal reduction in her overall

compensation each year between 2007 and 2017. She also alleged

that, when the County repealed the Supplemental Ordinance

effective December 20, 2016, the County, once again, illegally

reduced her compensation in violation of Ga. Const. of 1983, Art. VI,

Sec. VII, Par. V.

The trial court rejected all of Cowen’s claims, concluding in

part that: (1) Cowen’s mandamus action was barred by gross laches;

(2) even if the mandamus action was not barred, it was subject to

dismissal because mandamus was not an appropriate vehicle

through which Cowen could seek her back pay; and (3) even if

mandamus were an appropriate vehicle, the mandamus action was

without merit.

Cowen appeals, and, for the reasons that follow, we conclude

that (1) some, but not all, of Cowen’s claims for back pay were time

2 The exact language of these provisions will be addressed later in this

opinion. 2 barred; and (2) the trial court erred in concluding that mandamus

was not an appropriate vehicle here; but (3) the trial court properly

denied the claim for mandamus. Accordingly, we affirm.

1. Cowen claims that the trial court erred when it determined

that her mandamus action was barred by gross laches. In its order,

the trial court concluded that, because Cowen waited until 2017 to

file her mandamus action, which included some claims for back pay

dating as far back as 2007, then all of her claims for back pay were

barred by gross laches. As explained more fully below, this broad

conclusion by the trial court was incorrect.

Because mandamus is a quasi-equitable remedy, such an

action “can be barred by gross laches.” (Citation omitted.) Marsh v.

Clarke County School Dist., 292 Ga. 28, 30 (732 SE2d 443) (2012);

OCGA § 9-3-3 (“[C]ourts of equity may interpose an equitable bar

whenever, from the lapse of time and laches of the complainant, it

would be inequitable to allow a party to enforce his legal rights.”).

See also West v. Fulton County, 267 Ga. 456, 458 (1) n. 3 (479 SE2d

722) (1997) (“[M]andamus as a remedy may not lie where an

3 applicant is guilty of gross laches or has permitted an unreasonable

period of time to elapse”) (citation omitted). However, in reaching its

conclusion that the action here was barred, the trial court ignored

the two-year statute of limitation of OCGA § 9-3-22 that actually

applies in this case. In this regard, OCGA § 9-3-22 provides in

relevant part:

[A]ll actions for the recovery of wages, overtime, or damages and penalties accruing under laws respecting the payment of wages and overtime shall be brought within two years after the right of action has accrued.

See City of Atlanta v. Adams, 256 Ga. 620, 620-621 (351 SE2d 444)

(1987) (two-year statute of limitation of OCGA § 9-3-22 applied to

claims for back pay by firefighters who were paid pursuant to

municipal ordinance). See also Buskirk v. State of Ga., 267 Ga. 769

(2) (482 SE2d 286) (1997); Milhollin v. Salomon Smith Barney, Inc.,

272 Ga. App. 267 (1) (612 SE2d 72) (2005). This two-year statute of

limitation applies to claims for the recovery of back pay where, as

here, a public officer’s compensation is fixed by law. See Johnson v.

Brooks, 139 Ga. 787, 791 (78 SE 37) (1913) (public officer’s

4 “compensation belongs to the office, and is an incident of his office,

and he is entitled to it . . . because the law attaches it to the office”)

(citation and punctuation omitted).

Because it is undisputed that Cowen’s compensation as a state

court judge is determined by state law,3 the Local Law, and the

Supplemental Ordinance, and that her claims for back pay are

rooted in the interpretation of these laws, Cowen’s claims are subject

to the two-year limitations period contained in OCGA § 9-3-22, and

any claims for back pay that accrued more than two years before

Cowen filed her mandamus action on October 6, 2017, are time

barred.4 See Adams, supra, 256 Ga. at 620.

3 See OCGA § 15-7-22.

4 Cowen makes no argument that the limitations period would somehow

have been tolled for any reason in this case, and we reject Cowen’s claim that her mandamus action was not subject to the two-year limitations period contained in OCGA § 9-3-22 because her claim was not for lost “wages,” but for lost “compensation.” This argument is without merit, as this Court has previously applied the two-year limitations period of OCGA § 9-3-22 to claims for back pay by salaried public employees who were not paid an hourly wage. Adams, supra, 256 Ga. at 620. See generally Buskirk, supra, 267 Ga. at 769 (applying two-year limitations period of OCGA § 9-3-22 to claims involving annual salary advances and referring to those salary advances as “wage increases”). Cf. OCGA § 48-7-100 (10) (For income tax purposes, “‘[w]ages’”

5 That being said, while the claims that arose before October 6,

2015 would be barred by the applicable statute of limitation, this

would not necessarily prevent Cowen from pursuing claims that

were, in fact, timely raised within the applicable limitations period.

See Clover Realty Co. v. J. L. Todd Auction Co., 240 Ga. 124, 126 (4)

(239 SE2d 682) (1977) (“Delay alone is never enough to show laches

where there is an applicable statute of limitation.”). And because the

County has failed to show harm from any delay in the filing of claims

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

Related

POLO GOLF AND COUNTRY CLUB HOMEOWNERS ASSOCIATION, INC. v. CUNARD
854 S.E.2d 732 (Supreme Court of Georgia, 2021)

Cite This Page — Counsel Stack

Bluebook (online)
306 Ga. 698, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cowen-v-clayton-county-ga-2019.