Piechoczek v. Jones - Paternity Appeal Dismissal

GA Court of Appeals Opinions

Filed March 31st, 2026

Detected March 31st, 2026

Summary

The Court of Appeals of Georgia dismissed Julianna Piechoczek's direct appeal in her paternity and child custody case (Docket No. A26A1258). The dismissal was based on the procedural ground that Piechoczek's pro se notice of appeal was a legal nullity because she was represented by counsel at the time of filing. The court reaffirmed established Georgia precedent that parties cannot file pro se pleadings while simultaneously represented by counsel.

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What changed

The Georgia Court of Appeals dismissed Case No. A26A1258, a direct appeal from a trial court ruling that awarded Tudor Jones primary physical custody of two minor children with joint legal custody to both parents. The appellate court held it lacked jurisdiction because Piechoczek's pro se notice of appeal was legally invalid under Romich v. All Secure, Inc. and In the Interest of N.C., which establish that a party represented by counsel cannot simultaneously file pro se documents. The underlying trial court had issued its final custody order on August 11, 2025, and Piechoczek filed her appeal on September 11, 2025.

Parties in Georgia family law proceedings who are represented by counsel must ensure their attorney files all notices of appeal. Filing documents pro se while represented violates procedural rules and renders those filings void. Litigants wishing to challenge custody orders must maintain consistent representation or properly discharge counsel before filing any documents. No appeal bond, fee refund, or reconsideration of the underlying custody ruling results from this dismissal—the trial court's August 2025 order remains in effect.

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March 31, 2026 Get Citation Alerts Download PDF Add Note

Julianna Piechoczek v. Tudor Jones

Court of Appeals of Georgia

Citations: None known
Docket Number: A26A1258
Disposition: Dismissed
Opinion
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Disposition

Dismissed

Combined Opinion

Court of Appeals
of the State of Georgia

ATLANTA,____________________
March 31, 2026

The Court of Appeals hereby passes the following order:

A26A1258. JULIANNA PIECHOCZEK v. TUDOR JONES.

Julianna Piechoczek and Tudor Jones are the parents of two minor children.
After Piechoczek filed a petition for paternity and child support, Jones filed an answer
and counterclaimed for custody. On August 11, 2025, the trial court entered a final
order, awarding the parties joint legal custody with Jones having primary physical
custody. On September 11, 2025, Piechoczek filed this direct appeal pro se from that
ruling.1 This Court, however, lacks jurisdiction.
Piechoczek’s pro se notice of appeal is a legal nullity, as she was represented by
counsel at the time it was filed. See Romich v. All Secure, Inc., 361 Ga. App. 505, 505
(863 SE2d 179) (2021) (“A layperson does not have the right to represent herself and
also be represented by an attorney. As a result, a party cannot attempt to represent
herself by filing pro se pleadings, while at the same time she is represented by counsel
of record.”) (citation and quotation marks omitted); In the Interest of N. C., 358 Ga.
App. 379, 379 (855 SE2d 379) (2021) (dismissing a direct appeal in a child custody
proceeding because the mother’s pro se notice of appeal, filed while she was
represented by counsel, was a nullity).

1
In Case Number A26A1266, Piechoczek seeks to appeal the trial court’s denial
of her motion for new trial.
We therefore lack jurisdiction to consider this appeal, which is hereby
DISMISSED. See Romich, 361 Ga. App. at 505; In the Interest of N. C., 358 Ga. App.
at 379.

Court of Appeals of the State of Georgia
Clerk’s Office, Atlanta,____________________
03/31/2026
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.