Sunbelt Rentals, Inc. v. All-South Subcontractors, Inc., A17D0387

All-South Subcontractors filed a putative class action against Sunbelt Rentals; the court has not yet ruled on class certification.
Sunbelt moved for an order limiting either party’s communications with potential class members, arguing unilateral contact could be coercive.
After a hearing, the trial court ordered that until a class-certification ruling, neither party may discuss the case with current or former Sunbelt customers.
The order expressly allowed ordinary-course business communications by Sunbelt, counsel-to-client communications by All‑South’s counsel, and formal discovery of customers.
Sunbelt sought discretionary appellate review, arguing the order is an interlocutory injunction (directly appealable); All‑South argued it was a discovery ruling requiring interlocutory appeal procedures.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court's no-contact order is an injunction/directly appealable	Order is a discovery ruling (not immediately appealable); Sunbelt needed interlocutory appeal procedure	Order prohibits future conduct and functions as an interlocutory injunction, so it is directly appealable under OCGA § 5-6-34(a)(4)	The Court of Appeals construed the order as an interlocutory injunction and granted discretionary review; Sunbelt given 10 days to file notice of appeal

Dolinger v. Driver, 269 Ga. 141 (1998) (substance of an order controls its characterization; adversarial hearing supports injunctive nature)
Massey v. Butts County, 275 Ga. App. 478 (2005) (prohibition of future conduct is characteristic of injunctive relief)
Morgan v. U. S. Bank Nat. Assn., 322 Ga. App. 357 (2013) (interlocutory injunctions are directly appealable)