Board of Regents of the University System of Georgia v. Gonyea, No. A26A0594, 2026 WL 1883060, __ S.E.2d __ (Ga. Ct. App. June 30, 2026). The court (Doyle, P.J.; Davis, J., and Senior Judge C. Andrew Fuller concur) reverses the denial of the defendant's motion to dismiss. The plaintiff mailed her ante litem notices to a claims adjuster at a Lawrenceville address rather than to the Risk Management Division of the Department of Administrative Services at the Atlanta address required by statute. Ms.** 1–2. The court held that actual notice does not cure the failure to mail notices to the statutorily required recipient and address. Strict compliance with OCGA § 50-21-26(a)(2) remains a condition of the State's waiver of sovereign immunity; harmless-error and lack-of-prejudice reasoning do not apply. Ms.** 2–3.
