Kelvin Callaham v. Georgia Ports Authority

CourtCourt of Appeals of Georgia
DecidedMay 17, 2016
DocketA16A0238
StatusPublished

This text of Kelvin Callaham v. Georgia Ports Authority (Kelvin Callaham v. Georgia Ports Authority) 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
Kelvin Callaham v. Georgia Ports Authority, (Ga. Ct. App. 2016).

Opinion

THIRD DIVISION MILLER, P. J., MCFADDEN and MCMILLIAN, 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

May 17, 2016

In the Court of Appeals of Georgia A16A0238. CALLAHAM v. GEORGIA PORTS AUTHORITY.

MCFADDEN, Judge.

Kelvin Callaham appeals the dismissal of his personal injury action against the

Georgia Ports Authority. On appeal, he argues that when taken together, two

documents, a letter to the Ports Authority’s insurance adjuster and a notice of claim

to the Risk Management Division of the Department of Administrative Services,

satisfied the ante litem notice requirement of the Georgia Tort Claims Act, OCGA §

50-21-20 et seq. We disagree. OCGA § 50-21-26 (a) (2) of the Act provides that

when a person has a tort claim against the state, “a copy [of the person’s notice of

claim] shall be delivered personally to or mailed by first-class mail to the state

government entity, the act or omissions of which are asserted as the basis of the

claim.” Since Callaham did not mail or personally deliver to the Ports Authority a copy of the notice of claim he sent to the Risk Management Division, he did not

strictly comply with the requirements of that section. And because the duty to strictly

comply with those requirements cannot be excused on the basis of actual notice, the

letter to the adjuster does not supply that omission. Consequently, the trial court

properly dismissed his action.

On October 3, 2012, Callaham was injured in an auto accident at a Georgia

Ports Authority terminal in Savannah. Later that month, his attorney sent the first of

the two documents in question, a letter to a claims adjuster for the Georgia Ports

Authority. That letter advised her of his representation of Callaham and notified her

that Callaham had sustained injuries and was receiving medical treatment. The letter

included a copy of the police report and requested that the claims adjuster provide the

declaration page showing the policy limits of the insured’s automobile insurance

coverage. And it notified her that once Callaham had completed his medical

treatment, the attorney would forward to the claims adjuster his evaluation of the case

and demand. In June 2013, the attorney sent by certified mail the second of the

documents in question: Callaham’s notice of claim to the Risk Management Division

of the Department of Administrative Services.

2 In May 2014, he filed this action. The Georgia Ports Authority moved to

dismiss the complaint because Callaham failed to personally deliver or mail a copy

of the notice of claim to it as OCGA § 50-21-26 (a) (2) requires. The trial court

granted the motion, and Callaham filed this appeal.

On appeal, Callaham argues that his October 2012 letter to the Georgia Ports

Authority, combined with the June 2013 notice of claim sent to the Department of

Administrative Services constitute sufficient ante litem notice. OCGA § 50-21-26 (a)

(2), which is reproduced in full in the margin, requires a person with a tort claim

against the state to give written notice of the claim.1 The statute requires the claimant

to mail the notice by certified mail or statutory overnight delivery, return receipt

requested, or delivered personally to and a receipt obtained from the Risk

Management Division of the Department of Administrative Services. And it requires

1 “No person, firm, or corporation having a tort claim against the state under this article shall bring any action against the state upon such claim without first giving notice of the claim as follows: . . . Notice of a claim shall be given in writing and shall be mailed by certified mail or statutory overnight delivery, return receipt requested, or delivered personally to and a receipt obtained from the Risk Management Division of the Department of Administrative Services. In addition, a copy shall be delivered personally to or mailed by first-class mail to the state government entity, the act or omissions of which are asserted as the basis of the claim. Each state government entity may designate an office or officer within that state government entity to whom a notice of claim is to be delivered or mailed[.]” OCGA § 50-21-26 (a) (2) (emphasis supplied).

3 the claimant to deliver personally or by first-class mail a copy of the notice of claim

to the state government entity whose acts the claimant asserts to be the basis of the

claim. OCGA § 50-21-26 (a) (5), which is also reproduced in full in the margin,

requires the claimant to specify in the notice of claim certain items of information,

including the time, place, nature, and amount of the loss.2

To determine whether a claimant has complied with the ante litem notice

provision of the Act, we must look “to the plain meaning of the statutory language.”

Williams v. Georgia Dept. of Human Resources, 272 Ga. 624, 625 (532 SE2d 401)

(2000). And “the [Georgia] Tort Claims Act, by its own terms, must be strictly

construed.” Howard v. State of Ga., 226 Ga. App. 543 (1) (487 SE2d 112) (1997). In

this case, although Callaham properly sent his notice of claim to the Risk

Management Division of the Department of Administrative Services, he did not

personally deliver or mail a copy of his notice of claim to the Georgia Ports

Authority. He argues that his October 2012 letter to the Authority satisfies that

2 “A notice of claim under this Code section shall state, to the extent of the claimant’s knowledge and belief and as may be practicable under the circumstances, the following: (A) The name of the state government entity, the acts or omissions of which are asserted as the basis of the claim; (B) The time of the transaction or occurrence out of which the loss arose; (C) The place of the transaction or occurrence; (D) The nature of the loss suffered; (E) The amount of the loss claimed; and (F) The acts or omissions which caused the loss.” OCGA § 50-21-26 (a) (5).

4 requirement, when combined with the notice to the Risk Management Division, but

the letter did not include all of the elements that must be included in a notice of claim.

See OCGA § 50-21-26 (a) (5). Callaham never sent to the Georgia Ports Authority

the notice required by the statute.

In Dempsey v. Bd. of Regents of the Univ. System of Georgia, 256 Ga. App.

291, 293-294 (568 SE2d 154) (2002), this court stated that the plain language of

OCGA § 50-21-26 (a) (2) provides that the notice “must be mailed by certified mail,

return receipt requested, or delivered personally to the Risk Management Division of

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Related

Williams v. Georgia Department of Transportation
619 S.E.2d 763 (Court of Appeals of Georgia, 2005)
Kim v. Department of Transportation
510 S.E.2d 50 (Court of Appeals of Georgia, 1998)
Howard v. State
487 S.E.2d 112 (Court of Appeals of Georgia, 1997)
Williams v. Department of Human Resources
532 S.E.2d 401 (Supreme Court of Georgia, 2000)
Dempsey v. BOARD OF REGENTS OF UNIVERSITY
568 S.E.2d 154 (Court of Appeals of Georgia, 2002)
Grant v. Faircloth
556 S.E.2d 928 (Court of Appeals of Georgia, 2001)
DeFloria v. Walker
732 S.E.2d 121 (Court of Appeals of Georgia, 2012)

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