Jeremy S. Ramsey v. Khadija Elyse Allen

Court of Appeals
of the State of Georgia

ATLANTA,____________________
February 05, 2026

The Court of Appeals hereby passes the following order:

A26A0433. JEREMY S. RAMSEY v. KHADIJA ELYSE ALLEN.

In February 2024, the trial court entered an order denying Jeremy Ramsey’s
petition for legitimation and reserved the issue of retroactive child support. In June
2025, the trial court entered an order awarding Khadija Allen with child support,
retroactive child support, and attorney fees pursuant to OCGA § 19-7-50. Ramsey
appeals, pro se. We lack jurisdiction.
Although OCGA § 5-6-34(a)(11) permits direct appeals from judgments or
orders in child custody cases, OCGA § 5-6-35(a)(2) requires a discretionary
application from “judgments or orders in divorce, alimony, and other domestic relations
cases[.]”1 (Emphasis supplied.) “A legitimation proceeding is a type of domestic
relations case” requiring a discretionary application. Brown v. Williams, 174 Ga. App.
604 (332 SE2d 48) (1985). Moreover, cases where the underlying subject matter is a
father’s obligation to pay child support can only be reviewed by discretionary
application. Booker v. Ga. Dep’t of Human Res., 317 Ga. App. 426, 427 (731 SE2d 110)
(2012). Nevertheless, “the ‘issue-raised-on-appeal’ rule applies to appeals from
orders or judgments in child custody cases. This means that the proper appellate
procedure to employ depends upon the issue involved in the appeal[.]” Voyles v.
Voyles, 301 Ga. 44, 47 (799 SE2d 160) (2017).
Ramsey has argued five enumerations of error, none of which call into question

1
We note that Ramsey describes this appeal as being taken from “a final
judgment in a domestic relations matter.”
any custody ruling. Voyles, 301 Ga. at 47. Custody is, therefore, not an issue on appeal
in this domestic relations action, and Ramsey was required to comply with our
discretionary appeal procedure. Id. “Compliance with the discretionary appeals
procedure is jurisdictional.” Smoak v. Dep’t of Human Res., 221 Ga. App. 257 (471
SE2d 60) (1996). Ramsey’s failure to follow the mandated procedure in this case
deprives us of jurisdiction to consider this appeal, which is hereby DISMISSED.

Court of Appeals of the State of Georgia
Clerk’s Office, Atlanta,____________________
02/05/2026
I certify that the above is a true extract from
the minutes of the Court of Appeals of Georgia.
Witness my signature and the seal of said court
hereto affixed the day and year last above written.

, Clerk.