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Sampson v. Georgia Dep't of Juvenile Justice

The trial court erred in dismissing the plaintiff's complaint against the Georgia Department of Juvenile Justice for alleged violations of the Georgia Open Records Act on res judicata grounds.

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Thomas G. Sampson II “Sampson” appeals the trial court’s grant of the Georgia Department of Juvenile Justice’s “DJJ” motion to dismiss his complaint alleging violations of the Georgia Open Records Act.1 Sampson contends that the trial court erred in 1 finding that res judicata barred his complaint, 2 finding that the complaint should be dismissed for insufficient service, and 3 failing to find an ongoing violation of the Open Records Act and, instead, concluding that same was irrelevant as to whether res judicata barred the action. Because we agree with Sampson that the trial court erred in dismissing his complaint, we reverse.

The record reflects that Sampson filed suit against the DJJ, alleging violations of the Open Records Act with regard to more than 20 requests for records from different juvenile-detention centers. Sampson asked that the trial court issue an injunction ordering production of the requested documents, a declaration that the DJJ’s alleged failure to respond was unlawful, as well as an award of attorney fees and expenses.

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