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Russell Carl Nast v. Lauren C. Nast - Divorce Appeal Dismissed

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Summary

Russell Carl Nast's direct appeal from an October 8, 2025 divorce judgment was dismissed by the Georgia Court of Appeals. The court held that appeals from divorce orders must proceed via discretionary application under OCGA § 5-6-35(a)(2), not direct appeal, and that compliance with the discretionary procedure is jurisdictional. Lauren Nast's motion to dismiss was granted; her motion for a frivolous appeal penalty was denied.

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GovPing monitors GA Court of Appeals Opinions for new courts & legal regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 310 changes logged to date.

What changed

The Court of Appeals dismissed a direct appeal from a divorce judgment because Georgia law requires divorce appeals to follow the discretionary application procedure under OCGA § 5-6-35(a)(2), not direct appeal. The court confirmed that compliance with the discretionary appeals procedure is jurisdictional, and failure to comply warrants dismissal. Russell Carl Nast's frivolous appeal penalty motion was denied. Practitioners filing appeals from divorce-related judgments or orders in Georgia superior courts should ensure they use the correct procedural vehicle, as direct appeals from such orders are jurisdictionally improper.

The dismissal has no precedential effect beyond the parties and does not alter substantive divorce or arbitration law. No compliance obligations are created for any regulated entity beyond the specific parties to the litigation.

Archived snapshot

Apr 22, 2026

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April 22, 2026 Get Citation Alerts Download PDF Add Note

Russell Carl Nast v. Lauren C. Nast

Court of Appeals of Georgia

Disposition

Dismissed

Combined Opinion

Court of Appeals
of the State of Georgia

ATLANTA,____________________
April 22, 2026

The Court of Appeals hereby passes the following order:

A26A1628. RUSSELL CARL NAST v. LAUREN C. NAST.

In this divorce case, Russell Carl Nast filed the instant direct appeal from the
trial court’s October 8, 2025 order confirming an arbitration award and granting a
divorce between him and Lauren Nast. Lauren Nast has filed a motion to dismiss the
appeal, arguing that the case is subject to the discretionary application procedure. We
agree.
“[G]iven that the underlying subject matter of this case was divorce, the
appropriate method for appeal from the [October 2025 order] was an application for
discretionary appeal pursuant to OCGA § 5-6-35(a)(2), which applies to appeals from
judgments or orders in divorce cases.” King v. King, 354 Ga. App. 19, 22(1) (840 SE2d
108) (2020) (footnote omitted). Because compliance with the discretionary appeals
procedure is jurisdictional, Smoak v. Dept. of Human Res., 221 Ga. App. 257, 257 (471
SE2d 60
) (1996), the motion to dismiss is hereby GRANTED, and this appeal is
hereby DISMISSED.
Lauren Nast’s motion for a frivolous appeal penalty is hereby DENIED.

Court of Appeals of the State of Georgia
Clerk’s Office, Atlanta,____________________
04/22/2026
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.

Named provisions

OCGA § 5-6-35(a)(2)

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Last updated

Classification

Agency
GA Court of Appeals
Filed
April 22nd, 2026
Instrument
Enforcement
Branch
Judicial
Legal weight
Binding
Stage
Final
Change scope
Minor
Document ID
A26A1628
Docket
A26A1628

Who this affects

Applies to
Consumers
Industry sector
9211 Government & Public Administration
Activity scope
Divorce proceedings Appeal filings
Geographic scope
US-GA US-GA

Taxonomy

Primary area
Judicial Administration
Operational domain
Legal
Topics
Civil Rights

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