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Cambre & Assocs., LLCv.Lazenby

CourtCourt of Appeals of Georgia
Docket No.A25A0935
DecidedNovember 3, 2025
Reporter377 Ga. App. 652; 922 S.E.2d 855; 2025 Ga. App. LEXIS 537; 2025 LX 428187; 2025 WL 3072566
JudgesGOBEIL, Judge. Barnes, P. J., concurs and Watkins, J., concurs in judgment only to Division 1 and dissents to Division 2.
Tags
CivilAttorney AdvertisingLawyer SolicitationCivil RICOPrivate Right of ActionUnfair CompetitionMotion to DismissAmbulance Chasing
Case Summary

A personal-injury firm filed a proposed class action against a competing firm and its personnel, alleging they obtained accident-victim information and used runners to solicit clients before other lawyers could reach them. It asserted claims based on alleged violations of solicitation laws and bar rules, along with a Georgia RICO theory based on unauthorized access to private data. The Court of Appeals reversed the denial of the defendants’ motion to dismiss, holding that the cited criminal statutes and professional rules did not create a private civil claim. It also held that the plaintiff lawyers’ alleged competitive injury was too indirect and speculative to establish proximate cause under RICO: the alleged acts targeted accident victims’ data, not the plaintiffs’ property. Watkins, J., concurred only in the Division 1 judgment and dissented from the RICO ruling.

Opinion

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