Davis v. Coleman, Warden

Hunter Mason Davis lost his habeas corpus case, which is a legal challenge to the lawfulness of someone's imprisonment, in Ware County. He tried to appeal to the Supreme Court of Georgia, but the court dismissed his appeal in September 2025 because his notice of appeal and his request for permission to appeal were filed too late. Davis asked the court to reconsider, arguing that the trial court's order was not officially filed until June 12, 2024, the date it reached the electronic filing system PeachCourt, rather than June 11, 2024, when the judge signed it and the clerk's office stamped it as filed. He claimed that a Georgia electronic filing statute set the later date as the official filing date, which would have made his July 12, 2024 filings timely. The court disagreed, explaining that the electronic filing statute he relied on applies to filings by attorneys, not to a court's own orders, and that the order was actually filed with the clerk on June 11, 2024, as shown by the file stamp on the order itself. Because the deadline to appeal habeas rulings is jurisdictional, meaning the court has no power to hear a late appeal, it denied his motion.

The court held that Georgia's electronic filing statute (O.C.G.A. § 15-6-11) governs filings submitted by attorneys and does not require or govern when a court's own order is deemed filed; the order here was entered when it was signed and filed-stamped by the clerk on June 11, 2024, making Davis's later appellate filings untimely.

The ruling clarifies that habeas litigants in Georgia must count their 30-day appeal deadline from the date a judge's order is stamped filed by the clerk, not from when an electronic filing service logs it, which matters for anyone relying on electronic court records to calculate deadlines.

Motion for reconsideration denied

1. The court examined Georgia's electronic filing statute (O.C.G.A. § 15-6-11(b)(1)) and found it applies only to pleadings and documents filed by attorneys in civil cases, not to a court's own orders.
2. Because no part of that statute or any other law required the court's order to be filed electronically, the court rejected Davis's claim that the electronic filing date controlled when the order counted as entered.
3. The court explained that under Georgia's Appellate Practice Act (O.C.G.A. § 5-6-31), a judgment is entered when it is signed by the judge and filed with the clerk, which here was shown by the file stamp on the order itself dated June 11, 2024.
4. Since the deadline to appeal a habeas ruling under O.C.G.A. § 9-14-52(b) is jurisdictional, meaning missing it strips the court of any power to hear the appeal, the court had no discretion to excuse Davis's late filings on July 12, 2024.
5. Applying that filing date, the court concluded Davis's notice of appeal and application for permission to appeal were filed one day beyond the 30-day deadline, so the earlier dismissal of his appeal was correct.

• habeas corpus appeal
• filing deadlines
• electronic filing
• certificate of probable cause