David Lee Couch, an inmate injured while painting a prison warden’s house, won a $105,417 premises-liability verdict against the Georgia Department of Corrections. Before trial, he had offered to settle for $24,000; after the Department rejected the offer and the verdict exceeded the statutory threshold, the trial court awarded Couch attorney fees and litigation expenses under OCGA § 9-11-68 (b), which authorizes fees after rejection of a qualifying settlement offer. The Supreme Court of Georgia held that the Georgia Tort Claims Act waived the Department’s sovereign immunity from that fee award. The statute operated as a procedural rule governing conduct in an authorized tort action, rather than as damages requiring a separate waiver. But the Court held that the fee amount was calculated incorrectly. A contingency-fee agreement could inform the reasonable value of counsel’s services, but it was not conclusive and could not substitute for evidence of hours, rates, or other value indicators. The recoverable fees also had to be limited to services performed from rejection of the settlement offer through entry of the trial judgment, not the entire litigation or post-judgment recovery. The Court affirmed in part, reversed the fee calculation, and remanded for recalculation; all Justices concurred.