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Ledee v. Devoe

The trial court properly charged on negligence per se because defendant's unauthorized practice of law in violation of O.C.G.A. § 15-19-51 a 3 directly caused the plaintiff's injuries from the dismissal of her underlying slip and fall claim.

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William A. Ledee appeals the trial court’s denial of his motion for judgment notwithstanding the verdict. Bertha Devoe filed this action against Ledee and two co-defendants, Martin Findley and James L. Gray, alleging fraud, breach of contract, breach of fiduciary duty, negligence, negligence per se based on the unauthorized practice of law, conspiracy, and negligent and intentional infliction of emotional distress. The court entered summary judgment in favor of Gray, and the case proceeded to trial against Ledee and Findley. The jury returned a general verdict in favor of Devoe, awarding $10,000 in compensatory damages and $100,000 in punitive damages against Ledee.1 The court denied Ledee’s motion for judgment notwithstanding the verdict. We affirm.

It is well settled that the standard of appellate review of the denial of a motion for j.n.o.v. is the any evidence test. Pulte Home Corp. v. Woodland Nursery & Landscapes, Inc., 230 Ga. App. 455, 456 2 496 SE2d 546 1998.

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