Publication Date
12-19-2025
Document Type
Survey Article
Abstract
The admissibility of evidence in Georgia civil litigation continues to rest on a foundational principle: deference to the trial court’s discretion. Georgia appellate courts have consistently reaffirmed that evidentiary rulings—particularly those involving complex or fact-sensitive considerations—will not be disturbed absent a clear abuse of discretion. This standard reflects the institutional competence of trial courts, which are uniquely positioned to evaluate the credibility of parties, assess the probative value of evidence, and manage the presentation of issues throughout the course of litigation. While portions of Georgia’s Evidence Code closely mirror the Federal Rules of Evidence—permitting persuasive use of federal case law in interpretation—the governing approach remains one of judicial restraint on appellate review, especially where the record supports the trial court’s reasoning.
From 2024 through 2025, this doctrinal deference has been applied with increasing prominence across a range of civil litigation contexts, including expert testimony under Daubert, discovery of sensitive medical and financial records, and the treatment of allegedly spoliated evidence. Notably, in City of Atlanta v. Perkins, the Court of Appeals of Georgia upheld the trial court’s evidentiary and spoliation rulings, reaffirming that the discretion of trial courts encompasses not only admissibility determinations but also the imposition of sanctions designed to address litigation misconduct. Likewise, in Medernix, LLC v. Snowden, the appellate court clarified the scope of the harmless error doctrine in the context of discovery disputes concerning medical settlements, emphasizing that errors in evidence admission do not warrant reversal unless prejudicial. Collectively, these cases underscore a broader jurisprudential trend: while Georgia law continues to evolve alongside federal evidentiary standards, the trial court’s gatekeeping role remains paramount in ensuring fairness, efficiency, and integrity in the adjudication of civil claims.
Recommended Citation
Hall, John E. Jr.; Henwood, W. Scott; and Mabe, Rebekah
(2025)
"Between Relevance and Remedy: Trial Court Discretion in Georgia Evidence Law,"
Mercer Law Review: Vol. 77:
No.
1, Article 15.
Available at:
https://digitalcommons.law.mercer.edu/jour_mlr/vol77/iss1/15