Court of Appeals of Georgia dismisses interlocutory application

GA Court of Appeals Opinions

Filed March 2nd, 2026

Detected March 3rd, 2026

Summary

The Court of Appeals of Georgia dismissed an interlocutory application filed by Traditions Health, LLC and other defendants. The dismissal was due to the trial court's certificate of immediate review being filed fifteen days after the order, exceeding the ten-day jurisdictional limit.

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What changed

The Court of Appeals of Georgia, in the case of Traditions Health, LLC v. Lacey Brown, has dismissed an interlocutory application filed by the defendants. The defendants sought to appeal the trial court's denial of their motion to dismiss a RICO claim. The dismissal was based on a jurisdictional defect: the certificate of immediate review was filed 15 days after the order, exceeding the 10-day requirement under OCGA § 5-6-34(b).

This ruling means the interlocutory appeal cannot proceed. For legal professionals involved in Georgia civil litigation, this serves as a reminder of the strict jurisdictional requirements for interlocutory appeals. Failure to adhere to these deadlines, such as the 10-day window for the certificate of immediate review, will result in dismissal, as demonstrated in this case.

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March 2, 2026 Get Citation Alerts Download PDF Add Note

Traditions Health, LLC v. Lacey Brown

Court of Appeals of Georgia

Citations: None known
Docket Number: A26I0127
Disposition: Interlocutory Application Dismissed
Opinion
Authorities (2)
Cited By (0)
Summaries (0)
Similar Cases (0)
PDF

Disposition

Interlocutory Application Dismissed

Combined Opinion

Court of Appeals
of the State of Georgia

ATLANTA,____________________
March 02, 2026

The Court of Appeals hereby passes the following order:

A26I0127. TRADITIONS HEALTH, LLC et al. v. LACEY BROWN et al.

Lacey Brown and Erin Goodemote (“Plaintiffs”) sued Traditions Health LLC,
Tonya Payne, and Hannah Rousey (“Defendants”) asserting several claims, including
one for alleged violations of Georgia’s RICO statute, OCGA § 16-14-1, et seq.
Defendants filed a motion to dismiss Plaintiffs’ RICO claim and on December 1, 2025,
the trial court entered an order denying that motion. The trial court issued a certificate
of immediate review on December 16, 2025, and Defendants then filed this application
for interlocutory appeal.1 We lack jurisdiction.
Under OCGA § 5-6-34(b), a party may seek interlocutory review only if the trial
court “certifies within ten days of entry” of the order at issue that immediate review
should be had. The requirements of OCGA § 5-6-34(b) are jurisdictional. Settendown
Pub. Utility v. Waterscape Utility, 324 Ga. App. 652, 653 (751 SE2d 463) (2013). Here,
the certificate of immediate review was filed fifteen days after entry of the order
Defendants seek to appeal.

1
Defendants filed their application in the Supreme Court, which transferred
the application to this Court. Case No. S26I0658 (Jan. 15, 2026).
Consequently, we are without jurisdiction to consider this application, which is hereby
DISMISSED. See Turner v. Harper, 231 Ga. 175, 175 (200 SE2d 748) (1973)

Court of Appeals of the State of Georgia
Clerk’s Office, Atlanta,____________________
03/02/2026
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.