Marcus Somerville sued Wanda White for repayment of a loan, and White asserted counterclaims arising from their former relationship. The trial court found that Somerville violated Georgia’s criminal statute prohibiting the nonconsensual electronic transmission of nude or sexually explicit images of an adult and awarded White compensatory and punitive damages. The Court of Appeals held that the criminal statute created no private civil cause of action. Georgia law does not permit a court to imply a civil remedy from a penal statute enacted after the legislature required an express private right of action, and the statute contained no such authorization. Because the compensatory award was unauthorized, the derivative punitive-damages award was also unauthorized. The court affirmed the judgment on the parties’ other claims but reversed the judgment and both damage awards based on the penal statute. The opinion carefully distinguished alleged facts supplied for context from facts established at trial because the record lacked a transcript. Two judges concurred.