Latium USA Trading, LLC v. Janay Smith

CourtCourt of Appeals of Georgia
DecidedMarch 1, 2024
DocketA23A1262
StatusPublished

This text of Latium USA Trading, LLC v. Janay Smith (Latium USA Trading, LLC v. Janay Smith) 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
Latium USA Trading, LLC v. Janay Smith, (Ga. Ct. App. 2024).

Opinion

SECOND DIVISION MERCIER, C. J., MILLER, P. J., and HODGES, J.

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

March 1, 2024

In the Court of Appeals of Georgia A23A1262. LATIUM USA TRADING, LLC v. SMITH.

MILLER, Presiding Judge.

In this contract case involving the sale of allegedly defectively installed

windows, the seller, Latium USA Trading, LLC (“Latium USA”) seeks review of the

trial court’s entry of a default judgment in favor of the buyer, Janay Smith. On appeal,

Latium USA argues that (1) the judgment is void for lack of personal jurisdiction; (2)

the trial court erred by denying its motion to open the default; (3) the trial court

awarded speculative damages unsupported by the evidence; and (4) the trial court

erred by failing to apportion fault and damages. Upon a thorough review of the record,

we reverse the trial court’s award of loss of use damages because the method used to calculate them was improper. We reject the remainder of Latium USA’s arguments

and otherwise affirm the trial court’s judgment.

According to Smith’s complaint, Latium USA is a Delaware limited liability

company that also goes by the name “All Seasons” or “Four Seasons.” In August

2020, Smith contacted Four Seasons to purchase specialty windows for sunrooms that

she was building at her house in Atlanta, Georgia, in the place of two existing decks.

Four Seasons referred Smith to their installer, 2HIRE US, LLC (“2HIRE”), and

2HIRE came to Smith’s house to assess the work and issue an invoice. Smith entered

into a contract with 2HIRE, wherein various construction and installation work was

supposed to be completed on the sunrooms using windows provided by Four Seasons,

and Smith received invoices from 2HIRE to complete such work. By 2022, after Smith

paid the full amount due of $85,365.20, however, her decks had been demolished

without work on the sunrooms being substantially near completion, no windows had

been delivered to her house, and 2HIRE and Latium USA failed to respond to her

subsequent notice of construction defects.

Smith filed the instant complaint, alleging claims of breach of contract and

negligence against Latium USA and 2HIRE as well as a claim for fraud against Latium

2 USA, 2HIRE, and 2HIRE’s manager Keith Kelchner, and she also sought attorney

fees. Smith served Kelchner and 2HIRE, but they failed to timely respond to the

complaint. Smith also served Latium USA via its registered agent in Wilmington,

Delaware, and it also failed to timely respond to the complaint. Smith therefore moved

for a default judgment against all defendants. In January 2023, two months after the

time to file the answer had lapsed, Latium USA filed a motion to open default, arguing

that the trial court lacked personal jurisdiction over it because it did not conduct any

business in the state of Georgia and did not have the requisite minimum contacts with

Georgia. Following a hearing, the trial court denied Latium USA’s motion to open

default and granted Smith’s motion for a default judgment against all defendants. The

trial court first concluded that jurisdiction was proper over Latium USA and that

Latium USA was a proper party to the suit. The trial court then entered judgment in

the amount of $209,793.23, jointly and severally against 2HIRE, Latium USA, and

Kelchner, with said damages consisting of the $85,365.20 that Smith had paid, $11,100

in damages to her property, $599 in expert fees, $12,947.75 in attorney fees, and

$110,784.23 for the loss of use of her property. This appeal followed.1

1 2HIRE and Kelchner did not join Latium USA’s notice of appeal, and so Latium USA is the only defendant on appeal. 3 1. Latium USA first argues that the default judgment against it must be set aside

because it is void on its face for lack of personal jurisdiction. Latium USA argues that

it is not a resident of Georgia and that none of the provisions of Georgia’s long-arm

statute apply to give the trial court jurisdiction over it. We determine that the trial

court properly exercised personal jurisdiction over Latium USA.

“A judgment void on its face may be attacked in any court by any person.”

OCGA § 9-11-60 (a). “The Supreme Court of Georgia has defined the term ‘void on

its face,’ as used in this subsection to mean ‘those judgments which lack either

personal or subject matter jurisdiction.’ Therefore, collateral attacks on judgments are

limited to circumstances where the trial court lacks either subject matter or personal

jurisdiction.” (Citations and punctuation omitted.) Walker v. Blackwell, 259 Ga. App.

324 (577 SE2d 24) (2003).

“During a hearing on the determination of jurisdiction, in personam jurisdiction

must be proven by a preponderance of the evidence.” (Citation omitted.) Carter v.

Heritage Corner, Ltd., 320 Ga. App. 828, 830 (2) (b) (741 SE2d 182) (2013). “A

defendant moving to dismiss for lack of personal jurisdiction bears the burden of

4 proving the absence of jurisdiction.” (Citation omitted.) LG Chem, Ltd. v.

Lemmerman, 361 Ga. App. 163 (863 SE2d 514) (2021).

Under Georgia’s long-arm statute, a Georgia court “may exercise personal

jurisdiction over any nonresident . . . as to a cause of action arising from any of the

acts, omissions, ownership, use, or possession enumerated in this Code section, in the

same manner as if he or she were a resident of this state, if in person or through an

agent, he or she [t]ransacts any business within this state[.]” OCGA § 9-10-91 (1).

This subsection “grants Georgia courts the unlimited authority to exercise personal

jurisdiction over any nonresident who transacts any business in this State. . . . to the

maximum extent permitted by due process.” (Citation and punctuation omitted.)

Innovative Clinical & Consulting Svcs., LLC v. First Nat. Bank of Ames, 279 Ga. 672,

675 (620 SE2d 352) (2005).

Regularly doing or soliciting business in the state, deriving substantial revenue from goods or services in the state, having agents or representatives or officers or employees in the state, maintaining an office in the state, and having subsidiaries or business affiliates in the state are factors most directly relevant to the existence of general jurisdiction. Factors such as regularly doing or soliciting business, or deriving substantial revenue from goods or services, in this state may, however, also be relevant in determining whether sufficient minimum

5 contacts exist for the purpose of supporting specific jurisdiction, where such activities relate to the suit at hand.

(Citations omitted.) Aero Toy Store, LLC v. Grieves, 279 Ga. App. 515, 521-522 (1) (631

SE2d 734) (2006).

In determining the boundaries of due process, we must apply the following three-part test: [j]urisdiction exists on the basis of transacting business in this state if (1) the nonresident defendant has purposefully done some act or consummated some transaction in this state, (2) if the cause of action arises from or is connected with such act or transaction, and (3) if the exercise of jurisdiction by the courts of this state does not offend traditional fairness and substantial justice.

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Latium USA Trading, LLC v. Janay Smith, Counsel Stack Legal Research, https://law.counselstack.com/opinion/latium-usa-trading-llc-v-janay-smith-gactapp-2024.