Jeremy S. Ramsey v. Khadija Elyse Allen

• Court: Court of Appeals of Georgia
• Decided: February 5, 2026
• Docket: A26A0433
• Status: Published

Opinion

Court of Appeals of the State of Georgia

ATLANTA,____________________ February 05, 2026

The Court of Appeals hereby passes the following order:

A26A0433. JEREMY S. RAMSEY v. KHADIJA ELYSE ALLEN.

In February 2024, the trial court entered an order denying Jeremy Ramsey’s petition for legitimation and reserved the issue of retroactive child support. In June 2025, the trial court entered an order awarding Khadija Allen with child support, retroactive child support, and attorney fees pursuant to OCGA § 19-7-50. Ramsey appeals, pro se. We lack jurisdiction. Although OCGA § 5-6-34(a)(11) permits direct appeals from judgments or orders in child custody cases, OCGA § 5-6-35(a)(2) requires a discretionary application from “judgments or orders in divorce, alimony, and other domestic relations cases[.]”1 (Emphasis supplied.) “A legitimation proceeding is a type of domestic relations case” requiring a discretionary application. Brown v. Williams, 174 Ga. App. 604 (332 SE2d 48) (1985). Moreover, cases where the underlying subject matter is a father’s obligation to pay child support can only be reviewed by discretionary application. Booker v. Ga. Dep’t of Human Res., 317 Ga. App. 426, 427 (731 SE2d 110) (2012). Nevertheless, “the ‘issue-raised-on-appeal’ rule applies to appeals from orders or judgments in child custody cases. This means that the proper appellate procedure to employ depends upon the issue involved in the appeal[.]” Voyles v. Voyles, 301 Ga. 44, 47 (799 SE2d 160) (2017). Ramsey has argued five enumerations of error, none of which call into question

1 We note that Ramsey describes this appeal as being taken from “a final judgment in a domestic relations matter.” any custody ruling. Voyles, 301 Ga. at 47. Custody is, therefore, not an issue on appeal in this domestic relations action, and Ramsey was required to comply with our discretionary appeal procedure. Id. “Compliance with the discretionary appeals procedure is jurisdictional.” Smoak v. Dep’t of Human Res., 221 Ga. App. 257 (471 SE2d 60) (1996). Ramsey’s failure to follow the mandated procedure in this case deprives us of jurisdiction to consider this appeal, which is hereby DISMISSED.

Court of Appeals of the State of Georgia Clerk’s Office, Atlanta,____________________ 02/05/2026 I certify that the above is a true extract from the minutes of the Court of Appeals of Georgia. Witness my signature and the seal of said court hereto affixed the day and year last above written.

, Clerk.