Slappey v. Slappey (2009)

Court: Court of Appeals of Georgia · Decided: March 20, 2009 · Docket: A08A1633 · Judge: Doyle.

Source note (2026-10-18):

  • Links on this page to https://static.case.law/ga-app/296/cases/0773-01.json are an (unofficial Caselaw Access Project copy, retrieved before 2026-10-18; host disallows automated access); no official or otherwise permitted full-text copy was located on 2026-10-18.

Facts and holding

A farmer sought a laborer’s lien on his son’s cotton-crop proceeds for planting and picking. A recorded lender requested the § 44-14-550 probable-cause hearing. The trial court rejected the lien; the Court of Appeals reversed and remanded.

Independent-contractor status alone did not defeat a laborer’s lien. The work’s nature and direct contractual relationship mattered. Minimal labor-apportionment evidence sufficed at probable cause, but the claimant still had to prove the labor component at a full hearing. The preliminary hearing examines facts supporting a valid lien, not merely an unpaid debt.

Limits and verification

The court expressly did not decide priority against the recorded lender; the lender could renew its full-hearing request. This is not authority that a laborer’s lien always defeats perfected financing. See georgia, equipment-and-machinery.

The full CAP opinion, including footnotes, was downloaded and read on 2026-10-17. good_law_status: needs_verification; no complete later-treatment audit was established.


Legal information, not legal advice. Verify current authority before relying on this summary.