Ronald S. Hunt v. Allstate Property and Casualty Insurance Company
CourtCourt of Appeals of Georgia
Date FiledAugust 31, 2026
DocketA27A0243
StatusPublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
Court of Appeals
of the State of Georgia
ATLANTA,____________________
August 31, 2026
The Court of Appeals hereby passes the following order:
A27A0242. RONALD S. HUNT v. HARRY SIMMONS et al.
A27A0243. RONALD S. HUNT v. ALLSTATE PROPERTY AND CASUALTY
INSURANCE COMPANY.
In this action for breach of contract and related claims, one defendant asserted
several counterclaims with his answer. On May 14, 2026, the trial court granted a
motion to dismiss filed by two of the four defendants. Pro se plaintiff Ronald Hunt
filed a notice of appeal as to that order on June 10, 2026. That appeal has been
docketed in this Court as Case No. A27A0242. On May 21, 2026, the trial court
granted motions to dismiss filed by the other two defendants.1 Hunt filed a notice of
appeal as to those two orders on June 17, 2026. That appeal has been docketed in this
Court as Case No. A27A0243. We lack jurisdiction over both appeals.
Under OCGA § 5-6-34(a)(1)(B), appeals generally may be taken from “[a]ll
final judgments, that is to say, where the case is no longer pending in the court
below.” In a case involving multiple parties or multiple claims, a decision adjudicating
fewer than all the claims or the rights and liabilities of fewer than all the parties is not
a final judgment. Johnson v. Hosp. Corp. of Am., 192 Ga. App. 628, 629 (385 SE2d 731)
(1989). For a party to obtain appellate review under such circumstances, there must
1
In one of those orders, the court also granted one defendant’s motion for
OCGA § 9-15-14 attorney fees in an amount to be determined. That ruling does not
impact the finality of the trial court’s orders. See generally Hill v. Buttram, 255 Ga.
App. 123, 124 (564 SE2d 531) (2002) (reservation of OCGA § 9-15-14 attorney fees
issue does not extend the time to appeal).
be either an express determination by the trial court that there is no just reason for
delay under OCGA § 9-11-54(b) or compliance with the interlocutory appeal
requirements of OCGA § 5-6-34(b). See id. Where neither code section is followed,
the appeal is premature and must be dismissed. Id.
Here, the record contains no indication that the trial court directed the entry
of judgment under OCGA § 9-11-54(b) or that the remaining counterclaims in this
action otherwise have been disposed of. Consequently, because no final judgment has
been entered, Hunt was required to follow the interlocutory appeal procedures —
including obtaining a certificate of immediate review from the trial court — to appeal
the orders at issue here. See OCGA § 5-6-34(b); Boyd v. State, 191 Ga. App. 435, 435
(383 SE2d 906) (1989). His failure to do so deprives us of jurisdiction over these direct
appeals, which are hereby DISMISSED. See Bailey v. Bailey, 266 Ga. 832, 833 (471
SE2d 213) (1996).
Court of Appeals of the State of Georgia
Clerk’s Office, Atlanta,____________________
08/31/2026
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.