Grady A. Roberts III v. First Georgia Community Bank, 335 Ga. App. 228

First Georgia Community Bank sued Metropolitan Home Builders (MHB), Grady A. Roberts III (Roberts), and Sandra A. Murray (Murray) on a contract claim seeking a deficiency judgment.
MHB answered and counterclaimed; Roberts defaulted and a default judgment was entered against him on July 8, 2013; Murray was served later and remained a defendant.
Over a year later First Georgia filed a post-judgment motion (OCGA §§ 9-11-37, 9-11-69) to compel post-judgment discovery and seek sanctions for Roberts and Murray’s alleged failure to attend depositions and produce subpoenaed documents.
The trial court granted the motion to compel and imposed sanctions on November 12, 2014; Roberts and Murray did not object or file a response below.
On January 7, 2015 the court held Roberts and Murray in contempt; they appealed that contempt order (A15A1100) and separately appealed an order (Jan. 29, 2015) granting their supersedeas bond motion (A15A1101).
On appeal the defendants argued the court had no authority to grant post-judgment discovery/sanctions because there was no final judgment as to all parties and no civil case disposition form; the Court of Appeals concluded the issues were not preserved and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in granting the motion to compel and imposing sanctions where no final judgment had been entered as to all defendants	First Georgia argued post-judgment discovery and sanctions were authorized under OCGA §§ 9-11-69 and 9-11-37 to aid enforcement of the judgment against Roberts	Roberts/Murray argued the court lacked authority because there was no final judgment as to all defendants and no civil case disposition form filed under OCGA § 9-11-58(b)	Affirmed: defendants failed to preserve the issue by objecting below; appellate court refused to review issues not raised/rule d below
Whether the order granting the defendants’ supersedeas bond motion was reviewable on appeal	First Georgia implicitly contended prior rulings were proper and nothing barred relief	Roberts/Murray sought review identical to their first appeal arguments	Affirmed: same preservation problem — nothing for appellate review

King v. GenOn Energy Holdings, 323 Ga. App. 451 (recognizes waiver by failure to timely and specifically object)
Alston & Bird LLP v. Mellon Ventures II, L.P., 307 Ga. App. 640 (trial error not reviewed on appeal when issue not raised below)
Lord v. Holland, 282 Ga. 890 (discusses finality and entry of judgments among multiple defendants)
Horesh v. DeKinder, 295 Ga. App. 826 (addresses OCGA § 9-11-58(b) and entry requirements for judgments)
Wyatt Processing, LLC v. Bell Irrigation, Inc., 298 Ga. App. 35 (appellate courts do not review issues not raised and ruled on below)
Crippen v. Outback Steakhouse Intl., 321 Ga. App. 167 (scope of appellate review limited to issues presented to trial court)