Gowdy v. Schley, 317 Ga. App. 693

Deshanda Schley sued Travis Gowdy in Muscogee County, Georgia, seeking damages from a Alabama-based automobile collision.
Both Gowdy and Schley reside in Russell County, Alabama; the collision occurred in Alabama.
Gowdy was personally served in Muscogee County after being contacted there while avoiding service at his Georgia residence.
Gowdy moved to dismiss or transfer for improper venue or for forum non conveniens; trial court denied the motion.
Georgia intermediate appellate review granted Gowdy interlocutory appeal to address proper venue where an out-of-state plaintiff sues an out-of-state defendant for an Alabama crash.
The court held venue proper in Muscogee County under OCGA § 9-10-33, because Gowdy was temporarily present in Georgia to accept service.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is venue proper in Muscogee County for this Alabama accident case?	Schley argues venue lies where defendant resides or where injury occurred.	Gowdy contends Georgia venue is improper since both parties reside in Alabama and injury occurred in Alabama.	Venue proper in Muscogee County; temporary Georgia presence suffices.
Should the case be dismissed or transferred under forum non conveniens?	Schley maintains forum in Georgia is appropriate given service and convenience.	Gowdy argues dismissal/transfer is warranted to avoid inconvenience and reflect local interests.	Trial court did not abuse its discretion; forum non conveniens dismissal denied.

Hopkins v. Hopkins, 237 Ga. 845 (Ga. 1976) (jurisdiction and venue principles)
Miller v. Bryant, 266 Ga. 584 (Ga. 1996) (venue requires proper court authority)
Schuehler v. Pait, 239 Ga. 520 (Ga. 1977) (venue dependency on subject matter and personal jurisdiction)
Weddington v. Kumar, 149 Ga. App. 857 (Ga. App. 1979) (importance of proper venue when defendant is resident elsewhere)
Hawthorn Suites Golf Resorts, LLC v. Feneck, 282 Ga. 554 (Ga. 2007) (sojourn concept and temporary presence for service)