GAMMA HOMES, LLC v. ATLANTA REAL ESTATE SPECIALTY GROUP, LLC

CourtCourt of Appeals of Georgia
DecidedJune 5, 2026
DocketA26A0226
StatusPublished

This text of GAMMA HOMES, LLC v. ATLANTA REAL ESTATE SPECIALTY GROUP, LLC (GAMMA HOMES, LLC v. ATLANTA REAL ESTATE SPECIALTY GROUP, LLC) 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
GAMMA HOMES, LLC v. ATLANTA REAL ESTATE SPECIALTY GROUP, LLC, (Ga. Ct. App. 2026).

Opinion

SECOND DIVISION DOYLE, P. J., DAVIS, J., and SENIOR JUDGE FULLER

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.gov/rules

June 5, 2026

In the Court of Appeals of Georgia A26A0226. GAMMA HOMES, LLC et al. v. ATLANTA REAL ESTATE SPECIALTY GROUP, LLC.

DOYLE, Presiding Judge.

Following a bench trial, the plaintiffs,1 a group of limited liability companies

controlled by Hans Klein for the purpose of owning and operating real estate

investment properties, appeal from the involuntary dismissal of their suit against

Atlanta Real Estate Specialty Group, LLC, (“ARESG”) under OCGA § 9-11-41(b).

They contend that the trial court erred because (1) there was evidence to support an

1 The plaintiffs are: Gamma Homes, LLC; Garden 443, LLC; Bristol Lands, LLC; JWest Investments, LLC; Horizon Listings, LLC; Barrel South, LLC; JCT Property, LLC; Fulton West Residential, LLC; White 44, LLC; Twelve Trees, LLC; Fremont Links, LLC; Seven Seven Line, LLC; Atmosphere Homes, LLC; WWK Attractive, LLC; Lawful Wheels, LLC; Channel TT, LLC; Discover Laurel, LLC; and Lawn Marcy, LLC (collectively, “the Plaintiffs”). award of damages, aside from certain disputed exhibits not admitted by the trial court;

(2) the disputed exhibits were nevertheless admissible both as (a) business records and

(b) as admissions by a party opponent; and (3) the plaintiffs have demonstrated a

viable claim for attorney fees under OCGA § 13-6-11. For the reasons that follow, we

reverse and remand for further proceedings.

In reviewing a bench trial, we view the evidence in the light most favorable to the trial court’s rulings, defer to the trial court’s credibility judgments, and will not set aside the trial court’s factual findings unless they are clearly erroneous. A trial court’s involuntary dismissal of a claim pursuant to OCGA § 9-11-41 (b)2 may be reversed only if the evidence demands a contrary finding. But a trial court’s conclusions of law are subject to de novo review[, a]nd the application of the wrong legal standard may be reversible error.

Smith v. Northside Hosp., Inc., 302 Ga. 517, 520 (807 SE2d 909) (2017) (cleaned up).

2 OCGA § 9-11-41(b) provides, in relevant part: After the plaintiff, in an action tried by the court without a jury, has completed the presentation of his evidence, the defendant, without waiving his right to offer evidence in the event the motion is not granted, may move for dismissal on the ground that upon the facts and the law the plaintiff has shown no right to relief. 2 The facts material to this appeal are undisputed. Through the Plaintiffs, Klein

owns and operates a number of residential rental properties in Atlanta.3 Each of the

Plaintiffs executed nearly identical property management agreements (“PMAs”) with

ARESG, operated by Robert Taylor, who provided property management services,

including collecting rent, paying expenses, and making monthly disbursements of

remaining balances to the property owner. Under the PMAs, ARESG deposited rent

payments into trust accounts, and ARESG was required to provide a “detailed

monthly accounting of funds ... received and disbursed on [o]wner’s behalf,” with the

remaining amount (over a certain balance) remitted to the owner monthly. To meet

the obligation to provide monthly accounting, Taylor granted Klein access to an

owner’s portal in a software platform called Buildium, which Taylor used to input

data and document income, expenses, and disbursements with the understanding that

it would provide this information to Klein. All of the data in Buildium was input by

Taylor.

For several years, this process ran smoothly, and Klein received consistent

monthly disbursements totaling approximately $30,000, reflecting the net proceeds

3 Many of the properties are single family homes, and some are apartment buildings with 16 to 18 units. 3 from the properties. Klein tracked the flow of money using statements prepared by

Taylor available in Buildium. But eventually, Klein decided to terminate ARESG’s

services due to Taylor’s alleged failure to maintain certain units and provided 60 days

notice thereof per the PMAs.

Klein requested the final monthly distribution for June 2023, which according

to Klein’s testimony, should have been approximately $34,000 based on the income

statements available in Buildium at that time. But as Klein concluded his relationship

with Taylor and ARESG, Taylor failed to make a final disbursement to Klein, and he

failed to provide a final accounting to Klein that would show the state of the accounts

associated with each property. By July 2023, Klein’s access to Buildium was

terminated, and the last available statement was for July 8, 2023. Klein had no way of

obtaining a final accounting other than by relying on Taylor, who ultimately never

provided one despite months of requests by Klein. But according to Klein’s testimony,

the documentation available to him showed that there was $34,000 in undistributed

income; $15,000 in cash in the bank; security deposits of $7,000; and $2,000 from

mistakenly prepaid rent (all sums totaling $58,000)— all of which should have been

returned to Klein.

4 In August 2023, Klein sent Taylor a demand letter explaining his belief that

Taylor was “holding approximately $60,000 and perhaps substantially more of my

funds from my rental properties.” Taylor responded by disputing Klein’s claimed

figure without providing any evidence, and he asserted that an audit was pending.

They continued exchanging emails, with Taylor assuring that he was working on a

final accounting but ultimately providing none and failing to give Klein access to

Buildium to assess the accounting himself.

Based on this failure to agree on a final accounting and disbursement, the

Plaintiffs sued ARESG, seeking damages for breach of the PMAs, promissory

estoppel, unjust enrichment, and attorney fees under OCGA § 13-6-11 (making fees

available for bad faith, stubborn litigiousness, or causing unnecessary trouble and

expense). During the ensuing bench trial, ARESG objected to the admission of three

exhibits, Plaintiffs’ Exhibits 8, 9, and 10 (“the Exhibits”), on hearsay grounds. The

exhibits were reports prepared by Taylor and obtained by Klein through his own

access to the Buildium application. The trial court excluded them, and at the close of

the Plaintiffs’ case in chief, ARESG moved to involuntary dismiss the case under

OCGA § 9-11-41(b). The trial court granted the motion on the ground that it could not

5 consider the Exhibits, and the record otherwise lacked “sufficient evidence to show

damages for any of the claims.” The Plaintiffs now appeal.

1. The Plaintiffs contend that, regardless of any evidentiary rulings as to the

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Bluebook (online)
GAMMA HOMES, LLC v. ATLANTA REAL ESTATE SPECIALTY GROUP, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gamma-homes-llc-v-atlanta-real-estate-specialty-group-llc-gactapp-2026.