Hampton Oaks Community Association, Inc. v. Mark Baker
CourtCourt of Appeals of Georgia
Date FiledSeptember 22, 2026
DocketA27D0111
StatusPublished
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Full Opinion
Court of Appeals
of the State of Georgia
ATLANTA,____________________
September 22, 2026
The Court of Appeals hereby passes the following order:
A27D0111. HAMPTON OAKS COMMUNITY ASSOCIATION, INC. v.
MARK BAKER et al.
Hampton Oaks Community Association, Inc. (“Hampton Oaks”) initiated this
litigation in superior court to recover unpaid assessments and attorney’s fees, and to
judicially foreclose on property owned by the defendants. When the defendants failed
to timely respond to the complaint, the trial court awarded Hampton Oaks a default
judgment without holding an evidentiary hearing as to damages. Hampton Oaks
moved to vacate that judgment due to the failure to hold a damages hearing, which the
trial court denied on May 19, 2026. Hampton Oaks moved for reconsideration, which
the trial court denied on August 17, 2026. Hampton Oaks then filed its application for
discretionary appeal. We lack jurisdiction.
An application for discretionary appeal must be filed within 30 days of entry of
the order sought to be appealed. OCGA § 5-6-35(d). The proper and timely filing of
an application for discretionary appeal is an absolute requirement to confer
jurisdiction upon this Court. Gable v. State, 290 Ga. 81, 82(2)(a) (720 SE2d 170)
(2011). Moreover, “[i]t is well settled that motions for reconsideration do not toll the
time period for filing a notice of appeal.” Harned v. Piedmont Healthcare Found., 356
Ga. App. 870, 872 (849 SE2d 726) (2020). See also Bell v. Cohran, 244 Ga. App. 510,
511 (536 SE2d 187) (2000) (an order denying a motion for reconsideration is not
appealable in its own right). In this case, Hampton Oaks’ September 1, 2026
application for discretionary appeal was filed 105 days after the May 19, 2026 trial
court order denying its motion to vacate, and is therefore untimely.1
Accordingly, this application for discretionary appeal is hereby DISMISSED.
Court of Appeals of the State of Georgia
Clerk’s Office, Atlanta,____________________
09/22/2026
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.
1
Hampton Oaks has not included the May 19, 2026 order, its motion to vacate,
or its motion for reconsideration in violation of Court of Appeals Rule 31(e) and (f).
Based on Hampton Oakss’ assertions in its application, it is questionable whether the
May 19, 2026 order was appealable because the original motion to vacate may not have
relied on OCGA § 9-11-60(d). See Bell, 244 Ga. App. at 511 (holding that a motion to
set aside that does not rely on OCGA § 9-11-60(d) is a discretionary motion and “the
denial of such a motion is not an appealable judgment” (quotation marks omitted)).
We need not address this issue, however, as this discretionary application is untimely.