Junior v. Graham

870 S.E.2d 378, 313 Ga. 420
CourtSupreme Court of Georgia
DecidedMarch 8, 2022
DocketS21G0578
StatusPublished
Cited by11 cases

This text of 870 S.E.2d 378 (Junior v. Graham) 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
Junior v. Graham, 870 S.E.2d 378, 313 Ga. 420 (Ga. 2022).

Opinion

313 Ga. 420 FINAL COPY

S21G0578. JUNIOR v. GRAHAM.

BETHEL, Justice.

This case involves the harmonization of two statutory

provisions. The first, OCGA § 13-6-11, authorizes a jury in a civil

suit to assess as damages certain legal expenses of a prevailing party

when that party has specifically requested them and when the jury

finds that the opposing party “has acted in bad faith, has been

stubbornly litigious, or has caused the plaintiff unnecessary trouble

and expense” prior to the initiation of litigation. The second, OCGA

§ 9-11-68 (b) (2), provides a sanction in the form of attorney fees and

litigation expenses incurred after the failure to accept what the

statute defines as a reasonable settlement offer. In Junior v.

Graham, 357 Ga. App. 815, 817-818 (849 SE2d 536) (2020), the

Court of Appeals determined that the sanction contemplated by

OCGA § 9-11-68 (b) (2) necessarily includes a set-off for the amount of damages awarded under OCGA § 13-6-11.

We granted certiorari to consider whether a plaintiff may

receive a full recovery under both statutory provisions. Because we

conclude that the provisions provide for different recoveries despite

using somewhat similar measures for calculating the respective

amount of damages or sanction, a prevailing plaintiff may recover

under each statutory provision without regard to any recovery under

the other. Accordingly, we reverse the decision of the Court of

Appeals and remand this case with direction that the case be

remanded to the trial court for reconsideration of the plaintiff’s

claim for attorney fees and litigation expenses pursuant to OCGA §

9-11-68 (b) (2) in a manner consistent with this opinion.

1. We begin by briefly discussing the history of this case.1 The

record shows that Joao Junior sued Sharon Graham for injuries

sustained from a car accident in 2010. Junior’s amended complaint

sought compensatory damages, punitive damages, and attorney fees

and litigation costs under OCGA § 13-6-11. After Junior filed suit,

1 The facts relevant to our analysis are not in meaningful dispute.

2 but before trial, Junior served Graham with a document styled

“Plaintiff’s Offer to Settle Tort Claim to Defendant Pursuant to

OCGA § 9-11-68.” Junior’s offer proposed to settle all of his claims

against Graham for $600,000. The offer was rejected by operation of

law after Graham failed to accept it within 30 days of its issuance.

See OCGA § 9-11-68 (c) (“An offer [of settlement] that is neither

withdrawn nor accepted within 30 days shall be deemed rejected.”).

The case proceeded to trial, where the jury found in Junior’s

favor and awarded him $3,000,000 in compensatory damages, plus

$1,200,000 in attorney fees and $51,554.95 in litigation expenses

pursuant to OCGA § 13-6-11. The attorney fee award was consistent

with Junior’s fee agreement with his counsel, which called for

counsel to be paid 40 percent of any compensatory damages award.

The combined total of attorney fees and litigation expenses awarded

by the jury was $1,251,554.95. This amount equaled Junior’s total

obligation for attorney fees and expenses of litigation preceding the

verdict in the case.

Because the jury’s award of compensatory damages exceeded

3 Junior’s offer to settle the suit for $600,000 by more than 125

percent, he filed a post-trial motion for attorney fees and litigation

expenses under OCGA § 9-11-68. That statute provides in relevant

part:

If a plaintiff makes an offer of settlement which is rejected by the defendant and the plaintiff recovers a final judgment in an amount greater than 125 percent of such offer of settlement, the plaintiff shall be entitled to recover reasonable attorney’s fees and expenses of litigation incurred by the plaintiff or on the plaintiff’s behalf from the date of the rejection of the offer of settlement through the entry of judgment.

OCGA § 9-11-68 (b) (2). Graham opposed the motion, arguing that

Junior’s settlement offer was not made in good faith, and that an

award under OCGA § 9-11-68 would give Junior a prohibited “double

recovery.”

The trial court, without holding an evidentiary hearing, denied

Junior’s motion and concluded that “allowing [Junior] a further

award of attorney’s fees would permit a double recovery.” The court

reasoned that even though OCGA §§ 9-11-68 (b) (2) and 13-6-11

contemplate awards based on different conduct, the total of attorney

4 fees and litigation expenses used to measure the awards was

incurred as to the same cause of action against the same defendant.

The court also determined that Junior had already been “fully

compensated” for the entire amount of attorney fees and litigation

expenses that he incurred in this lawsuit. On that basis, the court

determined that no additional recovery was permitted under OCGA

§ 9-11-68 (b) (2).2

Junior appealed the denial of his request for attorney fees and

litigation expenses under OCGA § 9-11-68 (b) (2), arguing that the

trial court erred by determining that the jury award under OCGA §

13-6-11 precluded the imposition of an award under OCGA § 9-11-

68 (b) (2). The Court of Appeals affirmed based on different

reasoning. See Junior, 357 Ga. App. at 817-818.

Specifically, the Court of Appeals rejected the trial court’s

2 The trial court did not decide if Junior’s offer of settlement was made

in good faith. See OCGA § 9-11-68 (d) (2) (“If a party is entitled to costs and fees pursuant to the provisions of this Code section, the court may determine that an offer was not made in good faith in an order setting forth the basis for such a determination. In such case, the court may disallow an award of attorney’s fees and costs.”). That issue may be addressed on remand. 5 rationale that receiving attorney fee and litigation expenses awards

under both OCGA § 13-6-11

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870 S.E.2d 378, 313 Ga. 420, Counsel Stack Legal Research, https://law.counselstack.com/opinion/junior-v-graham-ga-2022.