The Manifest Institute v. Coweta County Tax Commissioner
CourtCourt of Appeals of Georgia
Date FiledNovember 12, 2026
DocketA27D0305
StatusPublished
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Full Opinion
Court of Appeals
of the State of Georgia
ATLANTA,____________________
November 12, 2026
The Court of Appeals hereby passes the following order:
A27D0305. THE MANIFEST INSTITUTE et al. v. COWETA COUNTY TAX
COMMISSIONER et al.
Tion Parson, individually and as President of The Manifest Institute, applied
for discretionary appeal from a trial court order that dismissed the Institute’s action
without prejudice. The application materials show that the Institute is a non-profit
religious corporation and contain no indication that Parson is an attorney or a party
to the action.
To the extent Parson purports to represent the Institute, “only a licensed
attorney is authorized to represent a corporation in a proceeding in a court of record.”
Eckles v. Atlanta Tech. Group, Inc., 267 Ga. 801, 805(2) (485 SE2d 22) (1997). Further,
pursuant to Court of Appeals Rule 2(a), all filings submitted in this Court must be
signed “by an attorney of record, an attorney granted courtesy appearance, or pro se
party.” A court filing submitted by a non-attorney on behalf of another is ineffectual.
See Gamble v. Diamond “D” Auto Sales, 221 Ga. App. 688, 689(3) (472 SE2d 446)
(1996) (finding the notice of appeal filed by plaintiff’s non-attorney husband was
ineffectual). Accordingly, the discretionary application filed by Parson on behalf of the
Manifest Institute has no legal effect.
To the extent Parson seeks an appeal individually, there is no indication that
Parson is a party to the case or sought to become a party by way of intervention and
was denied the right to do so. Thus, Parson lacks standing to apply for discretionary
appeal. See Degussa Wall Systems v. Sharp, 286 Ga. App. 349, 350 (648 SE2d 687)
(2007) (“It is well-settled that only a party to the case can appeal from a judgment, or
one who has sought to become a party as by way of intervention and has been denied
the right to do so.” (quotation marks omitted)).
For these reasons, this application for discretionary appeal is hereby
DISMISSED. The applicants’ emergency motion for supersedeas is DENIED as
MOOT.
Court of Appeals of the State of Georgia
Clerk’s Office, Atlanta,____________________
11/12/2026
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.