Torres v. Pineda, [A25A1634, Jan. 27, 2026] __ S.E.2d __ (Ga. Ct. App. 2026).The court (Doyle, P.J.; Markle and Padgett, JJ., concur) affirmed. Applying the 2024 amendments to OCGA § 9-11-67.1, the court held that a binding settlement agreement is formed when the offeree provides written acceptance of all material terms enumerated in OCGA § 9-11-67.1(b)(1). The court explained that subsection (b)(1)(G) requires only a statement under oath regarding disclosure of insurance coverage that is delivered to the offeror, and does not require the statement to be oral, in person, or before a court reporter. Ms.*6.
The court further held that, under OCGA § 9-11-67.1(c), any term outside the material terms listed in subsection (b)(1) is immaterial, and variance from such a term does not constitute rejection of the offer. The offeror may not require settlement conditions that add to, waive, or modify the statutory requirements. OCGA § 9-11-67.1(e). Ms.**6–7.