In Cavalier Convenience v. Sarvis, 305 Ga. App. 141, 699 S.E.2d 104 (2010), a person injured in a car accident sued three defendants. Prior to trial, the plaintiff moved to preclude the issue of apportionment from being argued or submitted to the jury. The plaintiff in Cavalier argued that the entire Code section only applied when there was an allegation that the plaintiff was at least partially at fault for his or her own injuries. The Court held that the changes made to the Code section under the Tort Reform Act of 2005 showed that the legislature intended to require apportionment even in cases where the plaintiff was not alleged to be at fault. The court also found that OCGA 51-12-32, which provides a right of contribution, did not require a different result. Rather, its effect was limited by the 2005 amendments which added the words, "except as provided in Code Section 51-12-33." Cavalier, 305 Ga. App. at 145.