JENNIFER WARNER v. JEFFREY ESPITIA

CourtCourt of Appeals of Georgia
DecidedJune 20, 2025
DocketA25A0095
StatusPublished

This text of JENNIFER WARNER v. JEFFREY ESPITIA (JENNIFER WARNER v. JEFFREY ESPITIA) 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
JENNIFER WARNER v. JEFFREY ESPITIA, (Ga. Ct. App. 2025).

Opinion

FIFTH DIVISION MCFADDEN, P. J., HODGES and PIPKIN, 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

June 20, 2025

In the Court of Appeals of Georgia A25A0095. WARNER v. ESPITIA et al.

HODGES, Judge.

In this post-divorce action, Jennifer Warner filed a civil Georgia Racketeer

Influenced and Corrupt Organizations (“RICO”) Act complaint against Krystal

Kriewaldt and Jeffrey Espitia (collectively, “the defendants”) claiming that they

falsely accused her of being in arrears with her child support payments.1 The Superior

Court of Paulding County granted the defendants’ motion to dismiss Warner’s

complaint, and Warner appeals, essentially arguing that her complaint satisfied the

minimal pleading requirement to survive a motion to dismiss pursuant to OCGA § 9-

1 Warner is Espitia’s former spouse, and Kriewaldt is identified in the record as Espitia’s fiancé. 11-12 (b) (6). Because we conclude that Warner’s complaint far exceeds the scope of

the Georgia RICO Act, we affirm the trial court’s order dismissing the complaint.

Our standard of review is well settled:

Although a trial court’s ruling on a motion to dismiss for failure to state a claim is subject to de novo review, we accept the allegations of fact that appear in the complaint and view those allegations in the light most favorable to the plaintiff. Ultimately, any doubts regarding the complaint must be construed in favor of the plaintiff.

(Citations and punctuation omitted.) McLeod v. Costco Wholesale Corp., 369 Ga. App.

717, 718 (894 SE2d 442) (2023). So viewed, the record demonstrates that Warner and

Espitia divorced in 2009 and that the couple’s two children resided with Espitia and

his fiancé, Kriewaldt. A January 2023 child support consent order, entered by the

Superior Court of Cobb County (the “Cobb County court”), required Warner to pay,

initially, $450 per month to Espitia with an increase to $550 per month in November

2023. The child support order also noted that Warner was in arrears in the amount of

$7,500 as of July 1, 2022 and that she was required to pay Espitia an additional $100

per month until the arrearage was satisfied in full.

2 In June 2023, Espitia, with Kriewaldt’s assistance, filed a petition for contempt

in the Cobb County court, alleging that Warner was in arrears in the amount of

$11,774.58.2 At an October 25, 2023 hearing on Espitia’s petition for contempt,

Espitia admitted that he was “ignorant” as to whether Warner was in arrears or the

amount she was in arrears, but added that he did not “intentionally falsely swear”

because he “truly believed” Kriewaldt’s calculation of the alleged arrearage and

mistakenly thought that other expenses, in addition to child support, were in arrears.3

As a result, Espitia characterized the filings as “100 percent a mistake.”

After the hearing, the Cobb County court entered an order that declined to hold

Warner in contempt and, instead, awarded attorney fees to Warner against Espitia. As

part of its order, the Cobb County court concluded that Espitia’s contempt petition

had “such a complete absence of any justiciable issue of law or fact . . . that it could

2 During the same general time period, Espitia also filed a notice with the Georgia Department of Human Services asserting that Warner was in arrears; in turn, the Department notified Warner of its intent to suspend her driver’s license unless she satisfied the arrearage by one of several options. Warner requested a hearing before the Office of State Administrative Hearings, and Espitia filed a second notice with the Department in October 2023. The parties have not pointed us to any resolution of these notices contained in the record. 3 Kriewaldt did not attend the hearing. 3 not reasonably be believed that a court would find [Warner] in contempt. . . .” The

Cobb County court further found that

the claims in [Espitia’s] Petition were substantially frivolous, substantially groundless, and substantially vexatious. The [c]ourt [found] that the evidence showed the instant case was initiated with the intention to harass and intimidate [Warner]. [Espitia] testified under oath that he did not know the disputed child support payments, which had been adjudicated by [a] prior Consent Final Order, were res judicata. He further testified that [Kriewaldt] calculated the alleged arrearages in the Petition. The [c]ourt [did] not find these arguments credible or persuasive if true.

Thereafter, armed with the Cobb County court’s order, Warner filed the

present complaint alleging causes of action for filing false documents, violations of the

Georgia RICO Act, punitive damages, and attorney fees. The defendants moved to

dismiss Warner’s complaint, arguing that Warner’s claim was barred by res judicata

and because: (1) it violated the RICO Act’s purpose and codified public policy; (2)

Warner did not incur any damages; and (3) Warner’s true cause of action, if any, was

for abusive litigation, and she failed to satisfy the statutory prerequisites to maintain

such an action.

4 Following a hearing, the trial court granted the defendants’ motion to dismiss.

Specifically, the trial court found that the predicate acts underlying Warner’s RICO

claim — filing of false statements and writings (OCGA § 16-10-20) and filing false

documents (OCGA § 16-10-20.1) — were “specific intent crimes and require that a

person knowingly and willfully file documents and that the person knows the documents

contain false statements of material fact.” (Emphasis in original.) The court further

concluded that the pleadings from the Cobb County action demonstrated only that

Espitia “filed what he believed to be true and accurate documents with correct

information at the time he filed the documents[,]” such that “there could not be any

fact introduced to establish that [the defendants] knowingly made and filed false

documents, writings, or statements.” As a result, the trial court concluded that,

despite the Cobb County court’s finding that Espitia’s arguments were not “credible

or persuasive if true[,]” the predicate acts had not been shown and that Warner’s

RICO action failed. The trial court added that the RICO Act, “while liberally

construed, was not intended for use in civil matters of this scope.” This appeal

followed.

5 In her sole enumeration of error, Warner argues that she sufficiently pled a

claim for a Georgia RICO Act violation and that the trial court erred in granting the

defendants’ motion to dismiss on the basis that she failed to establish the defendants’

specific intent to commit the predicate offenses. Pretermitting any potential credibility

issues or factual conflicts, we conclude that Warner’s complaint exceeds the scope of

the Georgia RICO Act, such that the allegations of her complaint confirm that she

would not be entitled to relief. Therefore, we affirm.

(a) OCGA § 9-11-12 (b) (6) Generally. Georgia law provides that

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