Family Purpose Doctrine Georgia
In Parker v. Jester, 244 Ga. App. 494 (535 SE2d 814) (2000), a panel of this Court reversed the trial court's denial of summary judgment to the defendant father on the plaintiff's claim under the family purpose doctrine because there was no evidence that the defendant daughter was a member of the immediate household of her father. Id. at 495-496 (2).
The Court also noted that the defendant father was entitled to summary judgment on the family purpose doctrine claim for another reason:
"Since the plaintiff did not allege a cause of action under the family purpose doctrine in the original suit, the renewal provisions of OCGA 9-2-61 (a) did not protect this claim from the bar of the statute of limitation." Id. at 496, n. 2. Implicit in that conclusion is a finding that the family purpose doctrine is an entirely separate cause of action.