What did the court decide?

The Court of Appeals dismissed Jordan’s appeal because she filed a pro se notice of appeal while still represented by counsel, so the notice was ineffective and the court lacked jurisdiction.

Who is affected by this decision?

The decision affects Elizabeth Jordan (the appellant) and Jeffery May (the appellee); Jordan’s attempt to appeal the trial-court orders is ended unless she takes further action that cures the jurisdictional defect.

Because the appeal was dismissed for lack of jurisdiction, Jordan may seek to refile a valid appeal only after the trial court formally permits counsel to withdraw or after new appealable rulings are entered, subject to applicable deadlines.

On what legal grounds was the appeal dismissed?

The court relied on precedent holding that a represented party cannot file a pro se notice of appeal and that counsel must be formally allowed to withdraw before a party can represent themselves.

Can this dismissal be appealed?

Dismissal for lack of jurisdiction is generally final in this context; Jordan would need to address the jurisdictional defect (for example, obtain a formal withdrawal and then file a timely notice) rather than appeal the dismissal itself.

Elizabeth Jordan v. Jeffery May

Docket A26A0663

Court of record · Indexed in NoticeRegistry archive · AI-enriched for research

CivilDismissed

Filed: Apr 29, 2026 · 2 days ago
Jurisdiction: Georgia
Court: Court of Appeals of Georgia
Type: Opinion
Case type: Civil
Disposition: Dismissed
Docket: A26A0663

Appeal from a trial court order denying an amended motion for new trial, finding the appellant in contempt, and ruling on attorney-fee motions in a stalking protective order case

Summary

The Court of Appeals dismissed Elizabeth Jordan’s pro se appeal from a September 11, 2025 trial-court order concerning contempt and attorney-fee rulings because Jordan was still represented by counsel when she filed her notice of appeal. The court explained that a litigant cannot both proceed pro se and be represented by an attorney, and that a counsel withdrawal must be ordered by the trial court before a pro se filing can be effective. Because Jordan’s pro se notice of appeal was therefore a nullity, the appellate court concluded it lacked jurisdiction and dismissed the appeal.

Issues Decided

Whether a pro se notice of appeal filed while the appellant is represented by counsel confers appellate jurisdiction
Whether a party may represent herself on appeal before the trial court has formally permitted counsel to withdraw

Court's Reasoning

Georgia precedent holds that a party cannot simultaneously be represented by counsel and proceed pro se; a formal order permitting counsel to withdraw is required before a client may file pro se pleadings. Because Jordan filed a pro se notice of appeal while her attorney was still of record, that notice was a nullity and did not confer jurisdiction on the Court of Appeals. The court therefore dismissed the appeal for lack of jurisdiction.

Authorities Cited

Weinstock v. Small378 Ga. App. 319 (925 SE2d 760) (2026)
Romich v. All Secure, Inc.361 Ga. App. 505 (863 SE2d 179) (2021)
Hamilton Capital Group v. Equifax Credit Info. Servs.266 Ga. App. 1 (596 SE2d 656) (2004)

Parties

Appellant: Elizabeth Jordan
Appellee: Jeffery May
Attorney: Taylor Howard
Judge: Court of Appeals of the State of Georgia

Key Dates

trial court order date: 2025-09-11
pro se notice of appeal filed: 2025-09-19
counsel motion to withdraw filed: 2025-10-02
trial court granted withdrawal: 2025-10-15
appellate decision date: 2026-04-29

What You Should Do Next

1
Obtain formal withdrawal of counsel
Have counsel file a motion to withdraw in the trial court and obtain a signed order permitting withdrawal before attempting any pro se filings or notices of appeal.
2
Consult appellate counsel
Speak with an appellate attorney promptly to determine whether a new timely notice of appeal can be filed or whether other post-judgment remedies remain available.
3
Check appeal deadlines
Confirm applicable deadline dates for filing a new notice of appeal from the underlying September 11, 2025 order or any subsequent orders to avoid missing appeal periods.

Frequently Asked Questions

What did the court decide?: The Court of Appeals dismissed Jordan’s appeal because she filed a pro se notice of appeal while still represented by counsel, so the notice was ineffective and the court lacked jurisdiction.
Who is affected by this decision?: The decision affects Elizabeth Jordan (the appellant) and Jeffery May (the appellee); Jordan’s attempt to appeal the trial-court orders is ended unless she takes further action that cures the jurisdictional defect.
What happens next?: Because the appeal was dismissed for lack of jurisdiction, Jordan may seek to refile a valid appeal only after the trial court formally permits counsel to withdraw or after new appealable rulings are entered, subject to applicable deadlines.
On what legal grounds was the appeal dismissed?: The court relied on precedent holding that a represented party cannot file a pro se notice of appeal and that counsel must be formally allowed to withdraw before a party can represent themselves.
Can this dismissal be appealed?: Dismissal for lack of jurisdiction is generally final in this context; Jordan would need to address the jurisdictional defect (for example, obtain a formal withdrawal and then file a timely notice) rather than appeal the dismissal itself.

The above suggestions and answers are AI-generated for informational purposes only. They may contain errors. NoticeRegistry assumes no responsibility for their accuracy. Consult a qualified attorney before relying on them.

Full Filing Text

Court of Appeals
of the State of Georgia

ATLANTA,____________________
April 29, 2026

The Court of Appeals hereby passes the following order:

A26A0663. ELIZABETH JORDAN v. JEFFERY MAY.

In this stalking protective order case, the trial court issued an order on
September 11, 2025, in which it: (i) denied plaintiff Elizabeth Jordan’s January 2024
“Amended Motion for New Trial”; (ii) found Jordan in contempt of a prior order
awarding $5,000 in attorney fees to defendant Jeffery May; and (iii) denied May’s
February 2024 motion for OCGA § 9-15-14 attorney fees. At that time, Jordan was
represented by attorney Taylor Howard. On September 19, 2025, Jordan filed a timely
pro se notice of appeal. See OCGA § 5-6-38(a). On October 2, 2025, Howard filed a
motion to withdraw from her representation of Jordan. The trial court granted
Howard’s motion to withdraw on October 15, 2025. For the reasons that follow, we
lack jurisdiction over this pro se appeal.
Contempt rulings generally are directly appealable under OCGA § 5-6-34(a)(2).
See Hamilton Cap. Group v. Equifax Credit Info. Servs., 266 Ga. App. 1, 2–3(1) (596
SE2d 656) (2004). A layperson, however, may not represent herself and also be
represented by an attorney. Romich v. All Secure, Inc., 361 Ga. App. 505, 505 (863 SE2d
179) (2021). And “a formal withdrawal of counsel cannot be accomplished until after
the trial court issues an order permitting the withdrawal.” Id. (quotation marks
omitted). Consequently, Jordan’s pro se notice of appeal is a nullity, as she was
represented by counsel when she filed it. See Weinstock v. Small, 378 Ga. App. 319,
320 (925 SE2d 760) (2026) (“[A] pro se notice of appeal filed by a represented party
in a civil case[ ] is a legal nullity and does not confer appellate jurisdiction to this
Court.”); Romich, 361 Ga. App. at 505 (dismissing appeal because the appellant’s pro
se notice of appeal, filed while she was represented by counsel, was a nullity). We
therefore lack jurisdiction to consider this pro se appeal, which is hereby
DISMISSED. See Weinstock, 378 Ga. App. at 320; Romich, 361 Ga. App. at 505.
May’s motion to dismiss this appeal for other reasons is hereby DENIED as
MOOT.

Court of Appeals of the State of Georgia
Clerk’s Office, Atlanta,____________________
04/29/2026
I certify that the above is a true extract from
the minutes of the Court of Appeals of Georgia.
Witness my signature and the seal of said court
hereto affixed the day and year last above written.

, Clerk.