Publix Super Markets, Inc. v. Cobb County

CourtCourt of Appeals of Georgia
DecidedOctober 10, 2025
DocketA25A1018
StatusPublished

This text of Publix Super Markets, Inc. v. Cobb County (Publix Super Markets, Inc. v. Cobb County) 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
Publix Super Markets, Inc. v. Cobb County, (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

October 10, 2025

In the Court of Appeals of Georgia A25A1018. PUBLIX SUPER MARKET, INC. v. COBB COUNTY.

PIPKIN, Judge.

Publix Super Market, Inc. (“Publix”) appeals the dismissal of its declaratory

judgment action against Cobb County. For the reasons discussed below, we affirm.

The record shows that, in 2018, Cobb County officials engaged three private

law firms to investigate and prosecute claims related to the opioid epidemic in the

county. The law firms agreed to represent Cobb County on a contingent fee basis and

advance all of the costs of the mass tort litigation. That same year, the county

attorney, with the assistance of the private law firms, filed a public nuisance action in

the Northern District of Georgia, suing numerous manufacturers and distributors of

opioids on behalf of Cobb County. The case was transferred to the U.S. District Court for the Northern District of Ohio (Cleveland) as part of the national prescription

opioid multi-district litigation, and Publix was added to this mass tort action in 2019.

During the federal litigation in Ohio, Cobb County acknowledged that it had

engaged outside counsel to help represent it in the mass tort litigation. This caused

Publix to file a complaint for declaratory and injunctive relief in Cobb County Superior

Court against Cobb County in February 2023. Specifically, Publix sought a declaration

that Cobb County’s practice of hiring a private law firm on a contingency fee basis in

the opioid litigation was void ab initio, and that Cobb County violated Georgia

statutory law and the Georgia Constitution when it hired outside counsel to file and

prosecute the public nuisance lawsuit.1 Publix also sought injunctive relief for the same

claims. Cobb County filed a motion to dismiss for failure to state a claim, for lack of

subject matter jurisdiction, see OCGA § 9-11-12 (b) (1) & (6), asserted a claim of

sovereign immunity, and also filed a motion to strike the complaint pursuant to

1 More specifically, Publix cited OCGA § 41-2-2 (concerning the prosecution of public nuisance actions), § 36-10-1 (“All contracts entered into by the county governing authority with other persons in behalf of the county shall be in writing and entered on its minutes”), § 36-30-3 (a) (“One council may not, by an ordinance, bind itself or its successors so as to prevent free legislation in matters of municipal government”), § 36-60-13 (concerning counties entering into multi-year acquisitional contracts), and Ga. Const. of 1983, Art. IX, Sec. V, Par. 1 (the Debt Limitation Clause of the Georgia Constitution). 2 Georgia’s anti-SLAPP Act, see OCGA § 9-11-11.1. After a hearing, the superior court

granted the motion to dismiss.

On appeal, Publix asks this Court to reverse the superior court’s decision,

arguing that the superior court erred when it relied on the anti-SLAPP statue and in

finding that Publix’s complaint for declaratory relief failed to state a claim for relief.

While we disagree with some of the trial court’s reasoning, we agree with its ultimate

conclusion. Because Publix’s claims were “properly dismissed for a lack of

subject-matter jurisdiction, . . . we affirm the dismissal under the right-for-any-reason

doctrine.” Publix Super Market v. Rockdale County, 375 Ga. App. 94, 95 (913 SE2d 851)

(2025).

1. As an initial matter, we cannot ignore the import of this Court’s decision in

Publix Super Market v. Rockdale County. In that case, Publix filed a declaratory

judgment action against Rockdale County in the Rockdale County Superior Court

raising nearly identical issues regarding its hiring of a private law firm in the federal

opioid litigation. This Court affirmed the superior court’s dismissal of the case,

concluding, among other things, that Publix did not have statutory standing to bring

the declaratory judgment action. See id. at 97. Publix argues that Rockdale County is

3 factually distinguishable because, in that case, Rockdale County had dismissed its

federal court public nuisance action whereas, in this case, Cobb County’s public

nuisance action against Publix is still pending. While we acknowledge the different

procedural postures in these cases, based upon the record in this case and the law

regarding declaratory judgments and subject-matter jurisdiction, we disagree that the

legal analysis in Rockdale County is inapplicable here.2

2. Turning to the issue at hand, as this Court explained in Rockdale County,

The Declaratory Judgment Act (“the Act”) authorizes courts to declare rights and other legal relations of any interested party in cases of actual controversy under OCGA § 9-4-2 (a) and in any civil case in which it appears to the court that the ends of justice require that the declaration should be made under OCGA § 9-4-2 (b). Under OCGA § 9-4-2 (a), the idea of an actual controversy is often described as standing to bring the suit, and subsection (b) of the Act broadens the scope of the Declaratory Judgment Act beyond actual controversies to include justiciable controversies.

Our Supreme Court has defined the term “justiciable controversies” as the existence of circumstances showing a necessity for a determination of the dispute to guide and protect the plaintiff from uncertainty and insecurity with regard to the propriety of some future act or conduct, which is properly incident to his alleged rights and which if taken without direction might reasonably jeopardize his interest.

2 At oral argument, without any briefing on this issue or any stare decisis analysis, Publix asked this Court to reconsider and potentially reverse our decision in Rockdale County. We decline to do so. 4 And, although the Act is to be liberally construed, pursuant to OCGA § 9-4-1, no declaratory judgment may be obtained which is merely advisory, or fruitless, or which merely answers a moot or abstract question.

(Citations and punctuation omitted.) Id. at 96-97. “[T]he justiciability of a declaratory

judgment action presents a threshold question,” Perdue v. Barron, 367 Ga. App. 157,

163 (2) (885 SE2d 210) (2023), and because this case comes to us from the trial

court’s ruling on a motion to dismiss, we review that decision de novo, see Ashley v.

Carstarphen, 347 Ga. App. 457, 458 (820 SE2d 70) (2018). With these principles in

mind, we turn to the legal questions at issue.

(a) Actual Controversy

In order to have standing under OCGA § 9-4-2 (a), the party seeking relief must

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Bluebook (online)
Publix Super Markets, Inc. v. Cobb County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/publix-super-markets-inc-v-cobb-county-gactapp-2025.