Little v. Georgia DHS — appeal dismissed for failure to use discretionary appeal procedure

Case
Jimmy Michael Little, Jr. v. Georgia Department of Human Services, Division of Child Support Services
Court
Court of Appeals of Georgia
Judge
Not specified
Date Decided
August 17, 2026
Docket No.
A27A0175
Topics
Appellate jurisdiction; Discretionary appeals; Child support; Driver’s license suspension
Source
Read the full opinion

Background

In February 2025, an administrative law judge affirmed the suspension of Jimmy Little, Jr.’s driver’s license because of child-support arrears.

Little sought judicial review in superior court, which affirmed the administrative decision. He then filed a direct appeal to the Court of Appeals of Georgia.

The Court’s Holding

The Court of Appeals dismissed the appeal for lack of jurisdiction. An appeal from a superior court’s review of a state administrative-agency decision must proceed through Georgia’s discretionary-appeal procedure.

The court also explained that child-support matters are domestic-relations cases subject to that same procedure. Because Little did not follow it, the court lacked jurisdiction to consider his direct appeal.

Key Takeaways

  • Appeals from superior-court review of state administrative decisions require a discretionary application.
  • Child-support appeals are also subject to Georgia’s discretionary-appeal procedure.
  • Failure to use that procedure is jurisdictional and requires dismissal.

Why It Matters

The order underscores that the route of appeal is dispositive in administrative and child-support cases. Even after obtaining superior-court review, a party cannot invoke the Court of Appeals’ direct-appeal jurisdiction when a discretionary application is required.

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