Uber Technologies (ga), Inc. et al. v. Jane Doe #1, on Behalf of Jane Doe #14, a Minor

A woman sued Uber Technologies for a personal injury on behalf of a minor. During the lawsuit, Uber asked the trial court to issue a protective order stopping the other side from deposing Uber's CEO, arguing he had no unique personal knowledge of the relevant facts. The trial court denied the protective order and also refused to give Uber a certificate of immediate review, which is normally required before a party can appeal that kind of mid-case ruling. Uber then asked the Court of Appeals of Georgia for a stay, which was denied, and finally asked the Supreme Court of Georgia to take the case. The Supreme Court of Georgia denied Uber's petition for certiorari, meaning it declined to hear the case at all. Chief Justice Peterson wrote separately to explain that although the trial court's decision looked flawed and refusing the certificate seemed unwise, Georgia law simply does not give the appellate courts power to review this kind of ruling without that certificate.

Because the trial court denied Uber's request for a certificate of immediate review, neither the Court of Appeals nor the Supreme Court of Georgia had authority under Georgia's interlocutory appeal statute to review the denial of the protective order, so certiorari was properly denied.

The ruling reinforces that Georgia trial courts have broad control over discovery disputes like depositions of corporate executives, and parties cannot appeal those rulings unless the trial judge grants a certificate of immediate review. Litigants and businesses facing similar discovery fights have limited options to seek quick appellate relief.

Petition for certiorari denied

1. Georgia law generally limits appeals of mid-case rulings, like the denial of a protective order, to situations where the trial court grants a certificate of immediate review under Georgia's interlocutory appeal statute (O.C.G.A. § 5-6-34).
2. Here the trial court denied both the protective order sought by Uber and the certificate of immediate review, leaving Uber with no statutory path to appeal that ruling before the case ended.
3. Because the General Assembly, not the courts, decides which rulings can be appealed early, the Supreme Court of Georgia has no authority to review the merits of a denied protective order when no certificate was granted, even if the trial court's decision seemed wrong.
4. Separately, the concurrence noted that the legal standard for protecting a corporate officer from deposition, found in Georgia's civil discovery statute (O.C.G.A. § 9-11-26.1), asks whether the officer lacks unique personal knowledge of relevant facts, and the trial court's order never applied that standard.
5. The concurrence also raised, without deciding, whether the order could instead be treated as an immediately appealable 'collateral order,' but noted no notice of appeal appears to have been filed, so that path was not available on this record.

• Uber lawsuit
• CEO deposition
• protective order
• certificate of immediate review
• interlocutory appeal