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Georgia Department Of Human Services Et Al.v.Addison Et Al.

CourtSupreme Court of Georgia
Docket No.S18A0803
DecidedSeptember 10, 2018
JudgesSupreme Court of Georgia
Tags
CivilAdministrative LawGovernment LawConstitutional LawDue ProcessSovereign ImmunityStatutory InterpretationCivil ProcedureReversalVacaturRemand
Case Summary

Georgia teachers and administrators sued directly in superior court after the Department of Human Services placed their names in the Child Abuse Registry based on findings that they had failed to supervise students adequately. The statute gave each person notice and an administrative hearing, and the plaintiffs separately initiated that process but pursued constitutional challenges in court before it was completed. The Supreme Court of Georgia held that the superior court could not reach the merits. Some claims were barred by sovereign immunity, while the remaining claims should first have been raised in the pending administrative proceedings and reviewed through the statutory process. The trial court therefore erred by declaring the Registry statutes and rules unconstitutional and granting injunctive relief without resolving the administrative path. The Supreme Court reversed the portion of the order addressing the merits, vacated the constitutional declaration and injunction, and remanded with direction to dismiss the case. The Court expressed no opinion on the constitutional challenges themselves and distinguished a separate case in which a claimant had completed the administrative review process.

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Georgia Department Of Human Services Et Al. V. Addison Et Al. — The Atlanta Gleaner