Georgia Department of Public Safety v. Ragsdale., 347 Ga. App. 827

On October 30, 2014 Matthew Ragsdale was injured when Ross Singleton fled law enforcement.
Ragsdale sent an ante litem notice to DOAS on December 3, 2014 but it lacked required information; he later dismissed the initial suit for that deficiency.
In March 2017 Ragsdale sent a second ante litem notice and renewed his action against the Georgia Department of Public Safety (the State).
The State moved to dismiss, arguing the March 2017 notice was untimely because OCGA § 50-21-26(a) requires notice within 12 months.
Ragsdale argued OCGA § 9-3-99 tolled the ante litem notice period because his claim arose from an alleged crime (tolling lasted until prosecution concluded, up to six years).
The trial court denied the State’s motion; the Court of Appeals affirmed, holding tolling statutes apply to ante litem notice under the GTCA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether OCGA § 9-3-99 tolls the one-year ante litem notice requirement under OCGA § 50-21-26(a)	Ragsdale: § 9-3-99 tolls the ante litem notice period because his claim arose from a crime victim’s injuries	State: § 50-21-26(a) is an antecedent notice requirement, not a statute of limitations, so § 9-3-99 does not toll it	Court: Tolling provisions (including § 9-3-99) apply to ante litem notice periods under the GTCA; affirmed denial of dismissal

Harrison v. McAfee, 338 Ga. App. 393 (reaffirming that OCGA § 9-3-99 tolls limitations for claims by crime victims, including claims against noncriminal actors)
Columbia County v. Blanton, 304 Ga. App. 149 (discussed and effectively overruled on scope-of-tolling grounds)
Foster v. Ga. Regional Transp. Auth., 297 Ga. 714 (statutory tolling provisions applicable to GTCA claims under OCGA § 50-21-27(e))
Howard v. State, 226 Ga. App. 543 (ante litem notice treated like a statute of limitations and subject to tolling)
Stopanio v. Leon’s Fence & Guardrail, LLC, 346 Ga. App. 18 (remanded for reconsideration in light of Harrison)