Timothy Harris won a negligence action after a rear-end collision and received a $35,000 jury award. Before trial, he had made a $22,000 settlement counteroffer. The trial court denied his requests for attorney fees under Georgia’s settlement-offer statute and under the statute governing fees for litigation lacking substantial justification. The Court of Appeals affirmed in part and reversed in part. It held that Harris was not entitled to fees under the settlement-offer statute because the offer had not been rejected in the manner required by the statute and the recoverable fee period did not begin when Harris claimed. The court nevertheless reversed the denial of fees under the other statute because the trial court relied on an erroneous factual finding concerning testimony attributed to the jury foreman. The case was remanded for reconsideration of that fee request. The judgment was affirmed in part, reversed in part, and remanded with direction.