Department of Transportation v. Lajos Szenczi

CourtCourt of Appeals of Georgia
DecidedMarch 13, 2020
DocketA19A1905
StatusPublished

This text of Department of Transportation v. Lajos Szenczi (Department of Transportation v. Lajos Szenczi) 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
Department of Transportation v. Lajos Szenczi, (Ga. Ct. App. 2020).

Opinion

FOURTH DIVISION DOYLE, P. J., COOMER and MARKLE, 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. http://www.gaappeals.us/rules

March 13, 2020

In the Court of Appeals of Georgia A19A1905. DEPARTMENT OF TRANSPORTATION v. SZENCZI et al.

DOYLE, Presiding Judge.

After a jury trial regarding the amount of just compensation in a condemnation

proceeding affecting property owned by Lajos Szenczi,1 the Georgia Department of

Transportation (“DOT”) instituted this appeal. Although Szenczi failed to file a

timely notice of appeal from the petition for condemnation and declaration of taking,

the trial court granted his motion to set aside2 the final order and judgment and

allowed a jury trial as to the amount of just compensation. In its appeal, DOT argues

1 A suggestion of death for Szenczi was filed on January 3, 2017, and his estate was substituted as a party on July 10, 2017. 2 DOT claimed at oral argument and in its appellate brief that it requested of the trial court a certificate of immediate review of this ruling, but no record evidence supports this contention. that the trial court erred by setting aside the final order on the basis that OCGA §

32-3-8 (b) required DOT to effectuate service of process on the probate court or

guardian because Szenczi was disabled for purposes of that statute. For the reasons

that follow, we reverse.

“A trial court’s ruling on a motion to set aside a judgment under OCGA §

9-11-60 (d) (3) is reviewed for an abuse of discretion.”3 This Court affirms a trial

court’s determination of insufficient service of process “[a]bsent a showing of an

abuse of discretion. . . . The trial court as factfinder must decide whether the evidence

overcomes the facts reflected in a return of service, and we will uphold that finding

if it is supported by any evidence.”4

On December 9, 2013, DOT filed a petition for condemnation of real property

for .674 acres of property, including that of Szenczi, and paid $30,150 as its estimate

of just and adequate compensation into the registry of the trial court. According to a

3 Nadel v. Branch Banking &c., 340 Ga. App. 213, 215 (797 SE2d 140) (2017). 4 (Citations and punctuation omitted). Space Coast Credit Union v. Groce, 337 Ga. App. 24, 25 (785 SE2d 663) (2016) (reviewing sufficiency of process based on mental incompetency under OCGA § 9-11-4 in a case in which service papers were placed by the bed of a defendant in a nursing home “in his late 60s or early 70s, . . . [who was] sleeping in his bed[,] in and out of consciousness[,] and . . . unable to take the papers”).

2 sheriff’s return of service, a deputy sheriff personally served the petition on Szenczi

on December 16, 2013,5 and on April 21, 2014, the superior court entered a final

order and judgment, finding that no condemnee appealed the amount of just and

adequate compensation within the 30-day period.

On April 23, 2014, an attorney representing Szenczi filed a notice of appeal of

the petition and amount of just compensation, requesting a jury trial as to the value

of the property. On May 22, 2014, Attila Szenczi (“the son”), purporting to be

“attorney-in-fact for Lajos Szenczi” and represented by the same attorney as Szenczi,

also filed a notice of appeal from the petition, challenging the amount of just

compensation. Months later, on September 5, 2014, Szenczi filed a motion to set

aside the final order and judgment under OCGA § 9-11-60 (d), arguing that DOT was

aware that Szenczi was represented by the son during DOT’s pre-petition negotiations

surrounding the condemnation, and arguing that DOT was aware that Szenczi was

extremely sick. Szenczi argued that DOT should have served the son or the attorney

in addition to himself.

5 The sheriff’s return of service is date stamped by the court February 7, 2014, and the second line of the address for the party to be served contains “Jackson, GA 30233,” which was scratched through and “Covington” written under the original address.

3 In the motion to set aside, Szenczi argued that DOT acted fraudulently by (1)

personally serving Szenczi, and (2) failing to serve or notify either the son or the

attorney representing him in negotiations. Szenczi argued that DOT was actually

aware he was “an ailing man unable to manage his own affairs” and had received

correspondence to this effect from both the son and the attorney approximately six

months prior to serving the petition; attached to the motion were (1) the

correspondence between DOT, the son, and the attorney; (2) an affidavit from the son

stating that Szenczi “had periods [when] he [was] not cognizant of his surroundings

or capable of handling his own affairs”; and (3) a copy of the son’s power of attorney

for Szenczi. DOT responded, contending that the sheriff personally served Szenczi

as required by law, and Szenczi had not been adjudicated mentally incompetent,

although he was in a wheelchair at the time of service. DOT filed an affidavit of the

deputy who served Szenczi, which stated that although Szenczi answered the door

using a [wheelchair], he “identified himself . . . and was able to communicate in an

appropriately responsive manner. [Other than] being in a wheelchair, Mr. Sczenzi did

not appear to me to be laboring under any disability.”

The court held an initial hearing on the matter, the transcript of which does not

appear in the record, and the court requested additional briefing. In response to the

4 trial court’s request, Szenczi argued that DOT was aware that he was laboring under

a disability but did not serve the probate judge of the county as required by OCGA

§ 32-3-8 (b).

On March 11, 2015, after the second hearing on the matter raised in the

motions, a transcript of which again does not appear in the appellate record, the trial

court granted the motion to set aside the final order and judgment. In its order, the

trial court found that beginning on or about July 10, 2013, the son communicated with

the DOT, telling them to deal directly with him (or his attorney) instead of Szenczi,

concerning the condemnation of Szenczi’s property. The court found that based on

the statements of the son concerning Szenczi’s health at the time and the fact that the

deputy observed Szenczi in a wheelchair when he effectuated personal service,

Szenczi was laboring under “any disability whatsoever” under OCGA § 32-3-8 (b)

and thus, the DOT was required to have served the probate court of the county in

addition to serving Szenczi personally.

The case then proceeded to a jury trial in December 2018 to determine just and

adequate compensation, and the jury found in favor of Szenczi, awarding

compensation of $75,000.

5 DOT now appeals, arguing that the trial court erred by setting aside the final

order and judgment based on its finding that Szenczi was disabled and that, as a result

of his status as disabled, service of process was improper.

“The right to appeal to a jury from a declaration of taking is absolutely

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498 S.E.2d 94 (Court of Appeals of Georgia, 1998)
Space Coast Credit Union v. Groce
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Department of Transportation v. Lajos Szenczi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/department-of-transportation-v-lajos-szenczi-gactapp-2020.