Chapter 11. Civil Practice Act · Article 10. Forms · Last amended 1980 · Last verified July 17, 2026
In one sentenceO.C.G.A. § 9-11-109 supplies a sample complaint for a personal-injury negligence claim, alleging that the defendant negligently drove a vehicle into the plaintiff on a public street, describing the resulting injuries and medical expenses, and seeking a lump-sum judgment for damages and costs.
Full Text of § 9-11-109
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IN THE ______________________ COURT OF ______________________ COUNTY
A.B., STATE OF GEORGIA Plaintiff ) ) v. ) ) Civil action C.D., ) File no. ______________________ Defendant ) (Clerk will insert ) number.)
COMPLAINT The defendant C.D., herein named, is a resident of ______________________ (street), ______________________ (city), ______________________ County, Georgia, and is subject to the jurisdiction of this court.
1. On June 1, 1966, on a public highway called Broad Street in Athens, Georgia, defendant negligently drove a motor vehicle against plaintiff who was then crossing said highway.
2. As a result plaintiff was thrown down and had his leg broken and was otherwise injured, was prevented from transacting his business, suffered great pain of body and mind, and incurred expenses for medical attention and hospitalization in the sum of $1,000.00. Wherefore, plaintiff demands judgment against defendant in the sum of $10,000.00 and costs.
______________________ Attorney for plaintiff ______________________ Address
Plain-English Summary
Of every scenario collected in this article, none is more familiar than this one: a pedestrian struck by a careless driver. The form shows how little factual detail Georgia’s notice-pleading standard demands even for a claim that will eventually turn on disputed facts and expert testimony.
The first numbered paragraph states the date, names the public highway, and alleges that the defendant negligently drove a vehicle against the plaintiff while the plaintiff was crossing it. The second describes what followed — a broken leg and other injuries, an inability to carry on business, physical and mental pain, and a stated sum for medical attention and hospitalization.
The closing demand asks for a single lump-sum judgment plus costs. Notably absent is any separate request for interest or attorney fees, a contrast with the article’s contract-debt forms, which routinely ask for both. Tort damages here are wrapped into one figure rather than broken into components.
The dollar amounts printed in the form are placeholders. A plaintiff replaces them with the actual medical bills and claimed damages, while the underlying structure — date, location, negligent act, injury, damages, demand — supplies the template for pleading a negligence claim under the Civil Practice Act.
Frequently Asked Questions
What must the complaint allege about how the injury happened?
The date, the location on a public highway, and that the defendant negligently drove a vehicle against the plaintiff while the plaintiff was crossing.
What injuries does the sample complaint describe?
A broken leg and other injuries, an inability to conduct business, pain, and a stated sum for medical attention and hospitalization.
What relief does the plaintiff seek?
A lump-sum judgment amount and costs — notably, no separate demand for interest or attorney fees, unlike the article’s contract-debt forms.
Does the complaint have to prove fault in detail?
No. Alleging that the defendant “negligently drove” the vehicle against the plaintiff satisfies the short, plain statement standard; proof of fault comes later, at trial.
Must a plaintiff use the exact dollar figures in the form?
No. The amounts shown are placeholders that a plaintiff replaces with actual medical costs and claimed damages.
Amendment History
Ga. L. 1966, p. 609, § 109; Ga. L. 1980, p. 649, § 7.
Source & verification. Section text and amendment history are
reproduced verbatim from the Official Code of Georgia Annotated, published by the
Official Code of Georgia Annotated, Georgia Code Revision Commission / LexisNexis. Last verified July 17, 2026.
· Official source
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