Dana Street v. Charles L. Marks, IV — Georgia court dismisses divorce appeal for lack of jurisdiction

Case
Dana Street v. Charles L. Marks, IV
Court
Court of Appeals of Georgia
Judge
Not specified
Date Decided
August 21, 2026
Docket No.
A27A0184
Topics
Divorce; Appellate jurisdiction; Discretionary appeal
Source
Read the full opinion

Background

Dana Street, proceeding pro se, filed a direct appeal after the trial court denied her motion for a new trial and/or reconsideration. That motion followed the final judgment and decree in her divorce action.

Under Georgia law, appeals from judgments or orders in divorce, alimony, and other domestic-relations cases must proceed through an application for discretionary review rather than a direct appeal.

The Court’s Holding

The Court of Appeals of Georgia dismissed Street’s direct appeal for lack of jurisdiction. Street did not use the required discretionary-appeal procedure for a divorce case.

The court held that compliance with the discretionary appeals procedure is jurisdictional. Because Street filed a direct appeal instead of an application for discretionary review, the court lacked authority to consider the appeal.

Key Takeaways

  • Georgia divorce appeals generally require an application for discretionary review.
  • Using a direct appeal instead of the required procedure deprives the appellate court of jurisdiction.
  • The court dismissed the appeal without reaching the merits of the trial court’s ruling.

Why It Matters

The order underscores that the method of seeking appellate review in domestic-relations cases is jurisdictional in Georgia. Even a challenge to a post-judgment order denying a new trial or reconsideration must follow the discretionary-appeal process when it arises from a divorce action.

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