Voluntary Undertaking Supports Wrongful-Death Claim Against Non-Driver

Keais v. Kelley; Newsome v. Keais, Nos. 2026 WL 2056469 (Ga. Ct. App. July 15, 2026). The court (Davis, J.; Rickman, P.J., and Gobeil, J., concur) reversed the dismissal of plaintiffs wrongful death claim which alleged the defendant negligently assumed the duty to report the accident after being summoned to the scene by the driver. The court held that although mandate in OCGA § 40-6-270 to stop and render aid after an accident applies only to drivers, a non-driver may be liable for negligently undertaking the driver’s reporting and aid duties. **5–7.

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