Fulton County sought to condemn more than 12 acres owned by Dillard Land Investments for a library expansion. After a special master valued the property at $5,187,500 and the superior court entered a judgment conditioning title transfer on payment, the County did not pay the award; instead, it voluntarily dismissed the condemnation action. The trial court rejected the dismissal, but the Court of Appeals held that the County could dismiss because it had not paid the award or taken title. The Supreme Court of Georgia reversed. It held that a special master’s value award resolves the fundamental compensation issue in a condemnation action and has the same dispositive effect as an assessors’ award, even though the court must still enter a formal condemnation judgment and non-value objections may remain. Georgia’s general voluntary-dismissal precedents therefore barred unilateral dismissal once the condemnor knew the actual result on value. The Court distinguished the question of when the award becomes enforceable from the separate question of when dismissal becomes unavailable. The County could dismiss before the special master announced the award, but not afterward without the condemnee’s agreement or court permission. All Justices concurred.