Georgia Motorcycle Accident Case Law: 30 Court Decisions That Defend the Rider

A rider’s case in Georgia turns on the same questions as any traffic case, with a few that are particular to motorcycles: whether the other driver saw the bike in time, whether a rider may be crowded within a lane, what the helmet law requires, and what happens when the danger was a pothole, loose gravel or a government vehicle. The 30 appellate decisions below are grouped around those questions.

Some of these decisions defend riders directly: a motorcycle’s right to the full use of a lane, a rider’s right to have disputed facts decided by a jury, and a rider’s control over a settlement offer. Many others went against the rider, including verdicts for the other driver, summary judgments for employers and landowners, and dismissals of claims against government bodies for defective notice. Both kinds are included because both show where a rider’s claim stands. Each summary reports what the court decided and links to the opinion on the Supreme Court of Georgia’s website, in the Caselaw Access Project’s reporter text, or in the court’s own PDF as archived by CourtListener.

Turning Drivers and Intersections

In the five decisions below, involving turning, crossing or stalled vehicles and a disputed crash scene, the evidence about speed, distance and visibility decided the outcome.

1. Lozynsky v. Hutchinson (1981)

Lozynsky v. Hutchinson, 159 Ga. App. 715, Court of Appeals of Georgia, decided September 25, 1981

Karla Lozynsky had her left signal on and had slowed to about 5 mph, turning several feet into the other lane, when a motorcycle driven by Hutchinson swerved around her car, hit a pothole beside the highway and flipped, putting him and his passenger, Gwen Hairston, in a ditch. When Hairston sued Lozynsky, Lozynsky brought in Hutchinson as a third-party defendant, and the trial court granted him summary judgment. The testimony conflicted on the speed limit, 25 or 45 mph, and on how fast the motorcycle was going.

“Questions of negligence and proximate cause are peculiarly questions for the jury except in clear, plain, palpable and undisputed cases,” the Court of Appeals wrote, and it reversed the summary judgment that had been granted to the rider. The court knew of no rule giving a rider an absolute right to assume that other drivers will obey the law, and the rider had not shown that he was free of negligence.

2. Griffin v. Bremen Steel Co. (1982)

Griffin v. Bremen Steel Co., 161 Ga. App. 768, Court of Appeals of Georgia, decided March 5, 1982

A tractor-trailer driven for Bremen Steel turned left across a two-lane road into a gravel lot. The motorcyclist collided with another truck and died after about 30 days; he never made contact with the Bremen Steel vehicle. The company said its driver signaled and saw no traffic for 431 feet before turning and that the motorcycle came out of a curve at 50 to 60 mph where the posted limit was 25; the trial court granted it summary judgment.

The Court of Appeals reversed. Issues of negligence and comparative negligence “are ordinarily not susceptible of summary adjudication,” it noted, and the conflicting testimony about the facts, together with the conflicting testimony created by a reconstruction expert, meant the case had to be tried.

3. Wilson v. Childers (1985)

Wilson v. Childers, 174 Ga. App. 179, Court of Appeals of Georgia, decided January 29, 1985

Childers stopped at a stop sign, saw no traffic, pulled into the intersection and stalled. Two to three minutes later, a motorcycle carrying Wilson as a passenger struck the stationary car. The motorcycle’s operator testified that he and Wilson had been drinking beer and playing pool before the crash. He also testified that he saw the car stop, pull into the intersection and stall, and that drivers could see 300 to 400 yards down the road from the intersection.

A jury found for Childers. Construing the evidence in favor of the verdict, the Court of Appeals held that it “was sufficient to support the jury verdict,” and affirmed.

4. Carter v. Mayor & Aldermen of Savannah (1991)

Carter v. Mayor & Aldermen of Savannah, 200 Ga. App. 263, Court of Appeals of Georgia, decided June 10, 1991

Michael Carter was riding west on 66th Street in Savannah when he struck a car crossing from Sutlive Street. The stop sign that normally controlled Sutlive Street traffic was not in place. Carter sued the driver and the city on negligence and nuisance theories, and the trial court granted the city summary judgment on both.

The split result tracks the two theories. Under Georgia precedent, a city “may be held liable for damages it causes to a third party from the operation or maintenance of a nuisance, irrespective of whether it is exercising a governmental or municipal function,” and the Court of Appeals found jury questions on the nuisance claim, including whether the absence of the sign caused the injuries. There was evidence that the city knew vandals had uprooted signs at that intersection, had not set this sign in concrete as its own policy required, and that the sign had been missing for at least a week. It affirmed, however, that the city could not be held liable on a theory of “mere negligent erection and maintenance of the sign.” One of the three judges concurred in the judgment only, and the Court of Appeals has since described the decision as physical precedent only.

5. Drummond v. Gladson (1995)

Drummond v. Gladson, 219 Ga. App. 521, Court of Appeals of Georgia, decided October 20, 1995

Ronald Drummond’s motorcycle collided with Jimmy Lee Gladson’s pickup, and the jury found for Gladson. Drummond’s only argument on appeal was that the trial court should not have admitted a diagram the investigating officer prepared from physical evidence at the scene, including the motorcycle’s skid marks. The diagram indicated that Drummond had been riding on the wrong side of the road.

The trial court did not abuse its discretion in admitting the diagram, the Court of Appeals held, and Drummond’s failure to provide a transcript of all the evidence also stood in the way of reversal. The judgment was affirmed. Both of the other judges on the panel concurred specially.

Lane Rights and Helmets

The first two decisions below turn on O.C.G.A. § 40-6-312, on a motorcycle’s use of a lane, and O.C.G.A. § 40-6-315, on protective headgear; the third concerns helmet evidence outside those statutes. The statutory texts below are as the courts quoted them in 1990 and 1988. In the text published by FindLaw as current on March 28, 2024, the quoted sentence of § 40-6-312(a) is unchanged, while § 40-6-315(a) now refers to protective headgear that complies with standards “established by the commissioner of public safety” rather than the Board of Public Safety; the annual summaries of general statutes enacted in 2024, 2025 and 2026 list no amendment to either section.

6. Neiswonger v. Janics (1990)

Neiswonger v. Janics, 196 Ga. App. 607, Court of Appeals of Georgia, decided July 13, 1990

In a drizzling rain on a two-lane road, a van came up behind a motorcycle and tried to pass it by moving only to the left side of the same lane, without crossing the center line. The front of the van struck the left side of the motorcycle. The van driver, supported by the driver behind her, said the rider had turned from the right edge of the lane in front of her, and she admitted she was about one car length away when she first saw him. The jury found for the rider.

The Court of Appeals affirmed, reading the passing rules together with § 40-6-312(a) as it then read: “All motorcycles are entitled to full use of a lane, and no motor vehicle shall be driven in such a manner as to deprive any motorcycle of the full use of a lane.” One judge concurred in the judgment only and one dissented.

7. Ritter v. State (1988)

Ritter v. State, 258 Ga. 551, Supreme Court of Georgia, decided October 5, 1988

Donald Ritter was charged with riding his motorcycle without a helmet under § 40-6-315(a), which then provided that “[n]o person shall operate or ride upon a motorcycle unless he is wearing protective headgear which complies with standards established by the Board of Public Safety.” He admitted riding without one and argued that the statute exceeded the State’s police power because it protected only the rider.

The Supreme Court disagreed and affirmed his conviction. A rider without a helmet, the Court reasoned, faces dangers that may cause him to lose control and become a hazard to other motorists, and, as a treatise the Court quoted puts it, a “motorcyclist who endangers himself plainly imposes [economic] costs on others.”

8. Stockert v. Rogers (2021)

Stockert v. Rogers, No. A21A1047, Court of Appeals of Georgia, decided September 29, 2021

This case involved a motorized skateboard, not a motorcycle, but it addressed helmet evidence directly. Brydan Rogers, riding the skateboard on the Georgia Tech campus, collided in an intersection with Joseph Stockert on a bicycle and suffered skull and facial fractures. The trial court excluded evidence that Rogers was not wearing a helmet, borrowing a “public policy” from statutes that bar using helmet violations by young cyclists and electric bicycle riders as evidence of negligence.

Those statutes did not cover motorized skateboards, and the Court of Appeals held that a policy “imported” from them was not a valid legal basis for excluding evidence. It reversed the ruling, leaving the question of relevance for the trial court on remand.

Road Conditions and Government Defendants

Claims against the State, counties and cities over road hazards and government vehicles turn on immunity and on strict notice requirements. Three of the five decisions below went against the rider on those grounds, one split between a county and its employee, and one sent the notice question back to the trial court.

9. Williams v. Whitfield County (2008)

Williams v. Whitfield County, 289 Ga. App. 301, Court of Appeals of Georgia, decided January 24, 2008

Paul Williams was hurt in a motorcycle accident at the intersection of two county roads and sued the county, claiming that signs warning of a road closure were not placed as the traffic control manual required. He argued that the county had waived its sovereign immunity through a contractor’s excavator parked in the lane beyond the barricade to keep motorists from running off the road.

The trial court found fact questions about the signs but granted summary judgment on immunity, because “there was no motor vehicle in use at the time of, or involved in, the motorcycle accident.” The Court of Appeals affirmed. Because the accident occurred in 2004, the court applied the waiver statute as it read before a 2002 amendment took effect in 2005.

10. Shuman v. Dyess (1985)

Shuman v. Dyess, 175 Ga. App. 213, Court of Appeals of Georgia, decided June 24, 1985

Shuman’s motorcycle collided with a county-owned lowboy that a Chatham County public works employee, Dyess, was using to haul a bulldozer for repair. The trial court granted summary judgment to both the county and Dyess on governmental immunity.

The Court of Appeals divided the result. There was no evidence that the county had chosen to buy insurance for its vehicles, so its immunity stood. Driving the lowboy, however, involved no governmental discretion, since it “had to be done in compliance with the rules of the road,” and the court held that “the trial court erred in granting summary judgment to appellee Dyess on the basis of governmental immunity.”

11. DeFloria v. Walker (2012)

DeFloria v. Walker, 317 Ga. App. 578, Court of Appeals of Georgia, decided September 6, 2012

Rufus Walker alleged that a Department of Corrections vehicle struck him while he was riding his motorcycle in Toombs County in September 2009. He wrote to the Department of Administrative Services soon afterward and corresponded with a state claims official, who at one point offered $75,000. The Department of Corrections moved to dismiss, arguing that his complaint did not attach the notice of claim and the proof of delivery that the Georgia Tort Claims Act requires.

Citing the requirement of strict compliance with the ante litem notice provisions of O.C.G.A. § 50-21-26, the Court of Appeals vacated the order denying the motion to dismiss and remanded for entry of an order dismissing the complaint. The notice letter had not been sent by certified mail or statutory overnight delivery, return receipt requested, or delivered personally with a receipt, and nothing showed that a copy went to the Department of Corrections.

12. Georgia Department of Transportation v. Jackson (2024)

Georgia Department of Transportation v. Jackson, No. A24A0902, Court of Appeals of Georgia, decided October 28, 2024

Theresa Jackson alleged that she was injured on a motorcycle when she drove over a pothole, obscured by water, in the area between Interstate 20 and an exit ramp. Her ante litem notice was sent by certified mail to the Department of Transportation and to the risk management division of the Department of Administrative Services, with a copy by e-mail to the latter. The trial court denied the Department’s motion to dismiss and, on reconsideration, received a postal tracking record showing only “Label Created, not yet in system” and a statement from the Department of Administrative Services that it had received the notice by e-mail but not by certified mail.

The Court of Appeals reversed. Strict compliance with the notice requirements of O.C.G.A. § 50-21-26 is required, and “[e]ven when the [S]tate agency has actual notice, a claimant is not excused from strictly complying with the notice requirements.” The court also held that serving the lawsuit on the Department of Administrative Services after it was filed could not satisfy a notice requirement that must be met before suit. A concurring judge added that Jackson had not attached the certified mail receipt to her complaint.

13. Mayor & Aldermen of Savannah v. Pope (2025)

Mayor & Aldermen of Savannah v. Pope, No. A25A0929, Court of Appeals of Georgia, decided September 11, 2025

Tiffany Pope was riding with her husband on his motorcycle on River Street in October 2018 when a police officer abruptly stopped his patrol car in front of them to make a traffic stop. Her husband veered sharply, and the motorcycle slid and toppled. The city argued that her ante litem notice under O.C.G.A. § 36-33-5 was insufficient because it did not state a specific amount of damages, and the trial court treated the sufficiency of the notice as a question of fact.

The Court of Appeals vacated the order denying summary judgment and remanded for the trial court to determine whether Pope’s notice complied with § 36-33-5(e).

Hazards Created by Private Property

Private landowners and businesses can be responsible for conditions that reach the road. These two decisions let a rider’s claims go forward.

14. Clark v. Blue Circle, Inc. (1999)

Clark v. Blue Circle, Inc., 237 Ga. App. 1, Court of Appeals of Georgia, decided March 15, 1999

Brian Clark was rounding a curve on Glenwood Avenue at 25 to 30 mph, slowing for a light, when his motorcycle hit a patch of gravel near the entrance to Blue Circle’s plant and slid into its fence. He testified that he had seen gravel fall off the company’s dump trucks on that street “a couple of times.” The trial court granted the company summary judgment.

“Genuine issues of material fact remain as to [Blue Circle’s] liability,” the Court of Appeals held, and it reversed.

15. Keith v. Beard (1995)

Keith v. Beard, 219 Ga. App. 190, Court of Appeals of Georgia, decided November 29, 1995

John Keith was riding his motorcycle on State Route 14 in February 1991 when, he alleged, a driver pulled out of a commercial driveway into his path. The Keiths alleged that the driveway had been built without the required permits and in violation of Department of Transportation regulations, and they sued the property owners along with the driver and others. They settled with the Department of Transportation.

A state engineer testified that the driveway’s sight distance fell short of the minimum and that he would not permit it as built, and the owner admitted knowing of the danger from an earlier lawsuit. The Court of Appeals held that the property owners’ liability under these circumstances “is a jury question” and reversed summary judgment on that claim, but it affirmed summary judgment on punitive damages. One of the three judges concurred in the judgment only.

Police Pursuits and Use of Force

These two decisions involve riders caught up in law enforcement action, one as a bystander and one as the person being pursued.

16. Clayton County v. Segrest (2015)

Clayton County v. Segrest, 333 Ga. App. 85, Court of Appeals of Georgia, decided July 13, 2015

On I-75 in August 2008, a Clayton County officer began pursuing Lance Locke, whom he had seen speeding and cutting off another vehicle. During the pursuit, Locke’s vehicle struck James Segrest’s motorcycle, and Segrest died. His widow sued the county, contending that the officer showed reckless disregard for proper law enforcement procedures in deciding to start and continue the chase.

Evidence that the officer acted with reckless disregard in those decisions “presents a jury question,” the Court of Appeals held, and it affirmed the denial of the county’s summary judgment motion. It reversed in part the ruling on the county’s motions to disqualify two of the plaintiff’s experts, to the extent their opinions stated legal conclusions such as “reckless disregard.” One judge concurred in the judgment only, writing that the opinion therefore may not be cited as binding precedent.

17. Collins v. Schantz (2023)

Collins v. Schantz, No. A23A0741, Court of Appeals of Georgia, decided September 26, 2023

Matthew Schantz led police on a high-speed motorcycle chase, and Appling County Sheriff Benny Deloach fired buckshot that struck Schantz’s helmet, face and neck before Schantz lost control and crashed. After federal courts held the sheriff immune from Schantz’s federal claim, Schantz sued the sheriff’s estate in state court for battery, negligence and violations of the Georgia Constitution.

There was evidence that the shot that struck Schantz was fired from more than 50 feet as he was moving away and that the sheriff was never in the motorcycle’s path. The Court of Appeals held that a genuine issue of material fact on official immunity allowed the battery and negligence claims to proceed, but that the state constitutional claims were not viable, and it affirmed in part and reversed in part.

The Rider’s Own Fault and Proof of Cause

A rider’s claim can fail because a jury assigns the rider most of the fault, or because the evidence does not show how the rider was hurt or who caused it.

18. Young v. Griffin (2014)

Young v. Griffin, 329 Ga. App. 413, Court of Appeals of Georgia, decided October 29, 2014

Eugene Young testified that he was riding at 25 mph toward a railroad crossing when he saw James Griffin’s truck blocking his lane on the other side. Griffin was making a U-turn to avoid waiting for a train, and he and two other witnesses said the crossing arm had begun to descend before he turned; the investigating officer said Griffin and another driver told him at the scene that Young crossed as the arm was coming down. The jury found Young 51 percent negligent and Griffin 49 percent negligent, and judgment was entered for Griffin.

Young challenged the defense’s closing argument and three jury charges. Even assuming the argument was improper, the Court of Appeals held, it did not in reasonable probability change the result; two of the charges were supported by the evidence and the third was not reversible error. The judgment was affirmed.

19. Berry v. Hamilton (2000)

Berry v. Hamilton, 246 Ga. App. 608, Court of Appeals of Georgia, decided November 1, 2000

Wanda Martin was riding her motorcycle on I-285 at about 2 a.m. when she fell off and was killed, either by the fall or by being struck by one or more passing cars. A caller had reported a motorcycle on the side of the road with its lights flashing and no rider in sight. Her family sued a driver and two unknown drivers.

It had been raining, Martin was dressed in dark clothing, and the driver who ran over her testified without contradiction that he never saw her; no one could say whether she was alive when she was struck. The family produced no evidence sufficient to raise a question of fact on whether any of those drivers was negligent or was a proximate cause of her death, and the Court of Appeals affirmed summary judgment.

20. Mobley v. Nabisco, Inc. (2003)

Mobley v. Nabisco, Inc., 264 Ga. App. 352, Court of Appeals of Georgia, decided November 14, 2003

Katie Mobley’s husband, on a motorcycle, collided with a truck whose driver fled, and his body was thrown to the pavement; less than a minute later he was struck by a Nabisco truck. His widow sued Nabisco for wrongful death.

The claim required proof that he was alive when the Nabisco truck struck him, and, citing Berry v. Hamilton (No. 19 above), the court found none. The fact that his arm fell from his helmet to the ground, the court held, “without more, is not evidence that the victim was alive after the first impact,” and summary judgment for Nabisco was affirmed.

When an Employer or Owner Answers for the Driver

When the driver who hit a rider was at work, or appeared to be, the rider may sue the employer as well. In each of these five decisions, the employer or owner was not held responsible.

21. Graham v. Hospice Savannah, Inc. (2023)

Graham v. Hospice Savannah, Inc., No. A23A0430, Court of Appeals of Georgia, decided June 9, 2023

Keyana Mann, a certified nursing assistant for Hospice Savannah, was driving to work when her car collided with O’Brian Graham’s motorcycle, and he was killed. His widow argued that Hospice Savannah was vicariously liable, pointing to a job description requiring nursing assistants to use their personal vehicles for home visits.

The trial court granted the employer summary judgment, and the Court of Appeals affirmed, relying on precedent that “an employee’s trip is not a ‘special mission’ if it involves nothing more than travel to his or her usual place of work.”

22. Mannion & Mannion, Inc. v. Mendez (2020)

Mannion & Mannion, Inc. v. Mendez, No. A20A0452, Court of Appeals of Georgia, decided April 24, 2020

Loren Blunkall, a mechanic for Mannion & Mannion, was leaving the company’s lot for lunch in his girlfriend’s car when he pulled into an intersection and struck Jesus Mendez’s motorcycle. He had ordered a part for the company by phone about thirty minutes earlier, but no one had asked him to run an errand on this trip, and he was not paid for the hours he missed because of the crash.

The trial court denied the company summary judgment. The Court of Appeals reversed, concluding that there was no genuine issue of material fact about whether Blunkall was acting within the scope of his employment.

23. Wood v. B&S Enterprises, Inc. (2012)

Wood v. B&S Enterprises, Inc., 314 Ga. App. 128, Court of Appeals of Georgia, decided February 16, 2012

Francisco Esquibel, who had often worked for B&S Enterprises as an independent contractor, was driving several co-workers toward the company’s workshop in a vehicle the company’s owner had loaned him when he failed to notice that Daniel Wood had stopped his motorcycle to turn left; he never slowed and struck it from behind, killing Wood. Wood’s widow sued the company on a theory of vicarious liability, and the jury found for B&S.

She argued that the trial court should not have charged the jury on the “special mission” doctrine and should have charged that use of a cell phone may place a driver within the scope of employment. The Court of Appeals found no reversible error and affirmed the judgment for the company: there was no evidence that the company had asked Esquibel to drive his co-workers, and the cell phone objection was not preserved and in any event lacked support, because there was no evidence he was on the phone at the time of the crash.

24. Reese v. Georgia Power Co. (1989)

Reese v. Georgia Power Co., 191 Ga. App. 125, Court of Appeals of Georgia, decided March 17, 1989

A Georgia Power employee, Standley, was driving a company truck when he collided with Reese, who was riding his motorcycle. Standley’s affidavit stated that he took it upon himself to use the truck on his lunch hour to pick up family members and take them to lunch.

To hold an employer liable, the employee must have been “engaged in the master’s business and not upon some private and personal matter of his own,” the court explained, quoting an earlier decision, and it affirmed summary judgment for Georgia Power. Two of the nine judges dissented on that point, reasoning that Standley had a company vehicle so that he would be available for emergencies.

25. Grant v. Jones (1983)

Grant v. Jones, 168 Ga. App. 690, Court of Appeals of Georgia, decided November 1, 1983

Curtis Grant was riding his motorcycle on Skull Shoal Road in Wilkes County in April 1981 when a farm tractor in the right lane turned left in front of him without signaling. According to the farm owner’s affidavit, the tractor’s driver, Albert Jones, had been asked the day before to use it to cut grass and to return it by 5 p.m. Jones instead took the tractor on a drinking spree and was driving it back without headlights, under the influence of alcohol, when the collision occurred about seven hours after he had been told to return it. Grant sued the owners for negligent entrustment.

There was no evidence that the owner knew Jones had been drinking or was not competent to drive, and “there was no entrustment of the tractor to Jones at the time of the accident, as he had taken the vehicle without permission.” He was also outside the scope of any employment, which had ended the evening before, and summary judgment for the owners was affirmed. One of the three judges concurred in the judgment only.

Insurance and Settlement

One decision below turned on what uninsured motorist coverage reaches; the other on whether a rider’s settlement offer had been accepted.

26. Mough v. Progressive Max Insurance Co. (2012)

Mough v. Progressive Max Insurance Co., 314 Ga. App. 380, Court of Appeals of Georgia, decided February 27, 2012

A car driven by Richard Gear’s daughter collided with B. J. Mough’s motorcycle and did not stop. Mough later rode past the Gear home, and after he turned around at the end of the street, Richard Gear shot and killed him. His family sought damages from his uninsured motorist carrier.

UM coverage requires damages “arising out of the ownership, maintenance, or use” of an uninsured vehicle, which calls for only a “slight causal connection.” Even so, the court held that the father’s decision to shoot was independent of his daughter’s use of her car, and that Mough’s injuries were “too remote” from the vehicle’s use to fall within the coverage. Partial summary judgment for the insurer was affirmed.

27. Bennett v. Novas (2022)

Bennett v. Novas, No. A22A0361, Court of Appeals of Georgia, decided June 17, 2022

Luis Novas was riding his motorcycle on E.E. Butler Parkway near Gainesville in January 2020 when he was injured in a collision caused by Ronda Bennett. He offered to release Bennett and her insurer for the $25,000 policy limit, and the insurer responded by asking whether John Bennett, the named insured on the policy, could also be named on the release; it later sent a check purporting to accept. Bennett moved to enforce a settlement.

Asking to add a party the offer did not name was not a request for clarification, which the settlement statute protects, but a counteroffer, the court held, and because nothing in the record showed that Novas renewed his offer, no binding settlement existed. The Court of Appeals affirmed the denial of Bennett’s motion.

Defective Motorcycles and Off-Road Riding

The last three decisions move off the public road: a brake failure claim against a manufacturer, a competition injury at a riding facility, and a trail rider on private land.

28. Johns v. Suzuki Motor of America, Inc. (2020)

Johns v. Suzuki Motor of America, Inc., 310 Ga. 159, Supreme Court of Georgia, decided October 19, 2020

Adrian Johns was seriously injured in August 2013 when the front brake on his Suzuki motorcycle failed suddenly. He sued Suzuki’s manufacturing and distributing companies on a strict products liability design defect claim and two negligence claims.

The question for the Supreme Court was whether Georgia’s apportionment statute applies to a strict products liability claim. It held that O.C.G.A. § 51-12-33(a) does apply, so a plaintiff’s share of fault can reduce damages on such a claim, and it affirmed the Court of Appeals on that point. The reduction of the Johnses’ damages awards to reflect Adrian Johns’s share of fault was upheld.

29. Georgia Trails & Rentals, Inc. v. Rogers (2021)

Georgia Trails & Rentals, Inc. v. Rogers, No. A20A1705, Court of Appeals of Georgia, decided March 11, 2021 (with related appeals including Two Rivers Holding Co. v. Rogers, No. A20A1710)

Coleman Rogers was severely injured while competing in a motorbike event, and a jury awarded him and his parents $15 million. The defendants, companies and individuals connected with the Durhamtown riding facility, argued among other things that the evidence did not show they owned or controlled the facility.

The Court of Appeals held that those ownership and control arguments had been abandoned because the briefs offered no supporting evidence or authority, rejected the remaining challenges, and affirmed the judgments.

30. Harrison v. Plant Improvement Co. (2005)

Harrison v. Plant Improvement Co., 273 Ga. App. 884, Court of Appeals of Georgia, decided June 9, 2005

Daniel Harrison, 28, was riding his cousin’s new dirt bike on dirt roads in Gwinnett County when he died on land owned by Plant Improvement Company, where a cable had been strung between two posts across a trail. His widow sued the landowner, which responded that he was a trespasser to whom it owed only a duty not to injure him willfully or wantonly.

The trial court found no evidence that the cable was installed “for the deliberate purpose of doing injury to trespassers” and held that it was an open and obvious static condition rather than a hidden peril or mantrap. The Court of Appeals affirmed: a static condition creates liability to a trespasser only if it was placed with intent to harm, and there was no evidence of that intent or that the landowner had reason to expect motorcyclists on the trail. The court acknowledged that injury to a motorcyclist was foreseeable from a dirt-colored cable across a dirt trail, but that did not show intent.

How These Decisions Were Selected and Checked

Each summary was written from the text of the opinion itself rather than from secondary descriptions. Citations use the Georgia Reports or Georgia Appeals Reports where the reporter citation was available; more recent Court of Appeals decisions are cited by docket number and decision date. The summaries cover the issues discussed here and not every issue in each appeal. Statutory language is quoted as the court quoted it in the year of the decision. Research for this page was completed in September 2026.

Middle Georgia Firms With Published Motorcycle Accident Pages

The following Macon-area firms publish practice pages on motorcycle accident claims. The descriptions below are limited to what each firm’s own page states.

Brodie Law Group, according to its Macon motorcycle accident page, represents injured riders throughout Macon and Bibb County.

Reynolds, Horne & Survant describes on its motorcycle accident page the risks riders face on Macon roads such as Gray Highway, I-475 and Eisenhower Parkway.

Adams, Jordan & Herrington, P.C.‘s motorcycle accident page names Macon, Warner Robins, Milledgeville, Albany and the surrounding Middle Georgia counties as the areas where it represents injured motorcyclists and their families.

Prine Law Group states on its motorcycle accident page that it represents injured riders across Macon and Middle Georgia, and the page discusses the assumptions riders can face from adjusters and jurors.

Gautreaux Law states on its motorcycle accident page that it serves Macon and all of Georgia, and the page lists common causes of motorcycle crashes, including distracted driving and impaired driving.

About This Page

This page summarizes published appellate decisions for general information. It is not legal advice and does not describe how the law applies to any particular claim. Court decisions can be limited, distinguished or overruled, and statutes change; the outcome of a case depends on its facts and on the version of the law that applies to it.