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Knox v. State of Georgia

2023-05-31

Summary

Holding. The judgment of the trial court dismissing the complaint was affirmed on the basis that the case became moot once the Board of Regents adopted its own weapons policy consistent with the 2017 statutory amendment, rendering declaratory relief ineffective.

Five University of Georgia professors sued to challenge a 2017 state law that removed public colleges from the definition of "school safety zones," thereby decriminalizing firearm possession on university campuses. The professors argued this legislative change violated the separation of powers by usurping the Board of Regents' constitutional authority to independently govern and manage the university system. However, after the law took effect, the Board of Regents itself adopted a weapons policy that mirrored the statutory amendments, allowing licensed handgun carriers on campus subject to specified exceptions.

The Georgia Supreme Court affirmed the trial court's dismissal on mootness grounds. The court reasoned that because the Board had voluntarily adopted its own policy regarding firearms on campus, the professors' requested relief—a declaration that the 2017 amendment violated the separation of powers—would provide no practical benefit. Even if the court invalidated the statute, the Board's independently adopted policy would remain in effect as the source of the professors' alleged injury. The court distinguished separation-of-powers cases where legislative action directly caused harm, noting that here the Board's own governmental action, not the statute alone, created the challenged situation.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Mootness doctrine in declaratory judgment actions
  • Separation of powers between legislature and university governing board
  • Effect of a government entity's voluntary compliance with challenged legislation on justiciability

Procedural posture

The trial court granted the State of Georgia's motion to dismiss for lack of jurisdiction on mootness grounds, and the Georgia Supreme Court reviewed the dismissal on appeal.

Authorities cited

Opinion

majority opinion

NOTICE: This opinion is subject to modification resulting from motions for reconsideration under Supreme Court Rule 27, the Court’s reconsideration, and editorial revisions by the Reporter of Decisions. The version of the opinion published in the Advance Sheets for the Georgia Reports, designated as the “Final Copy,” will replace any prior version on the Court’s website and docket. A bound volume of the Georgia Reports will contain the final and official text of the opinion.

In the Supreme Court of Georgia

Decided: May 31, 2023

S23A0167. KNOX et al. v. STATE OF GEORGIA.

ELLINGTON, Justice.

Five University System of Georgia (“USG”) professors 1 filed

suit to block a 2017 statutory amendment that removed public

colleges and other public postsecondary educational institutions

from the statutory definition of “school safety zone.” Before the 2017

amendment, carrying or possessing a weapon on any real property

or in any building owned by or leased to any postsecondary

educational institution was a misdemeanor, and the 2017

amendment decriminalized that conduct. The professors alleged

that, as a result of the 2017 amendment, the Code requires the

1 The plaintiffs below are John Knox, Michael G. Noll, James Porter,

Laurel Robinson, and William B. Whitman. A sixth professor, Aristotelis

Santas, joined as a plaintiff in the professors’ first complaint, but he did not

join in the plaintiffs’ amended complaint.

Board of Regents, the USG, and USG institutions to permit persons

to carry or possess weapons on the campuses of public postsecondary

educational institutions, contrary to longstanding USG policies. The

professors sought a declaration that the statutory amendment is

unconstitutional as applied because it usurps the Board’s

constitutional authority to govern, control, and manage the USG

and its member institutions.

The trial court granted the State of Georgia’s motion to dismiss

the complaint and denied the professors’ request for declaratory

relief, ruling that the trial court lacked jurisdiction on three

alternative grounds, including mootness. Because the complaint

shows that the Board adopted gun-carrying policies consistent with

the 2017 statutory amendment, the question of whether the

amendment usurped the constitutional authority of the Board to

govern, control, and manage the USG and its member institutions

became moot. Consequently, the trial court lacked jurisdiction to

adjudicate the professors’ as-applied challenge, and we affirm the

judgment dismissing the professors’ complaint on that basis alone.

2

Georgia’s constitution provides for judicial review of statutes.

See Ga. Const. of 1983, Art. I, § II, Par. V (a) (Legislative acts in

violation of the constitution “are void, and the judiciary shall so

declare them.”). An action against the State of Georgia in the

superior court for a declaratory judgment is the appropriate

litigation mechanism for such review, and enforcement of

unconstitutional statutes may be enjoined. See Ga. Const. of 1983,

Art. I, § II, Par. V (b)2; OCGA §§ 9-4-2; 9-4-3. A declaratory judgment

may be entered, however, only in the case of an “actual controversy,”

OCGA § 9-4-2 (a), where the plaintiff needs “relief from uncertainty

and insecurity with respect to rights, status, and other legal

relations.” OCGA § 9-4-1. See Gwinnett County v. Blaney, 275 Ga.

696, 703 (1) (572 SE2d 553) (2002).

“[T]he proper scope of declaratory judgment is to adjudge those

2 We note that the professors name the State of Georgia as the only

defendant, and they claim that the State has waived sovereign immunity as to

their constitutional challenge, based on an amendment to the judicial review

paragraph, adding Art. I, § II, Par. V (b), that the people of Georgia ratified in 2020. Because we affirm the trial court’s dismissal on jurisdictional grounds,

we do not reach the parties’ arguments about whether Art. I, § II, Par. V (b)

applies to the professors’ claims. Likewise, we do not reach the issue of

standing.

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rights among parties upon which their future conduct depends.”

Sexual Offender Registration Review Bd. v. Berzett, 301 Ga. 391, 393

(801 SE2d 821) (2017) (citation and punctuation omitted). There can

be no actual or justiciable controversy if the questions in the case

have become moot. See id. “A petition for declaratory judgment is

moot when the relief, if granted, would have no practical effect on

the underlying controversy.” Id. In particular, a court “has no

province to determine whether or not a statute, in the abstract, is

valid[.]” Fourth St. Baptist Church of Columbus v. Bd. of Registrars,

253 Ga. 368, 369 (1) (320 SE2d 543) (1984). See also Berzett, 301 Ga.

at 396 (“[I]t is a settled principle of Georgia law that the jurisdiction

of the courts is confined to justiciable controversies, and we will not

decide the constitutionality of a law where no justiciable case or

controversy is presented.” (citation and punctuation omitted)).

When a petition for declaratory judgment is moot, the trial court is

required to dismiss the action. See id. at 395-396; see also Baker v.

City of Marietta, 271 Ga. 210, 214 (1) (518 SE2d 879) (1999) (“Where

the party seeking declaratory judgment does not show it is in a

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position of uncertainty as to an alleged right, dismissal of the

declaratory judgment action is proper[.]”).

In this case, taking the allegations in the professors’ amended

complaint as true,3 the complaint shows that there is no actual,

justiciable controversy to authorize declaratory relief. The complaint

alleges the following. The Georgia constitution endows the Board

with plenary authority over the USG and its member institutions. 4

3 See Sons of Confederate Veterans v. Henry County Bd. of Commrs., 315

Ga. 39, 63 (2) (c) (880 SE2d 168) (2022) (“At the motion to dismiss stage, we

accept as true all well-pled material allegations in the complaint.”); Ewing v.

City of Atlanta, 281 Ga. 652, 653 (2) (642 SE2d 100) (2007) (“In reviewing the

grant of a motion to dismiss, an appellate court must construe the pleadings in

the light most favorable to the appellant with all doubts resolved in the

appellant’s favor. A motion to dismiss should only be granted if the allegations

of the complaint, construed most favorably to the plaintiff, disclose with

certainty that the plaintiff would not be entitled to relief under any state of

provable facts.” (citation and punctuation omitted)).

4 See Ga. Const. of 1983, Art. VIII, § IV, Par. I (b) (“The government,

control, and management of the University System of Georgia and all of the

institutions in said system shall be vested in the Board of Regents of the

University System of Georgia.”) (amendment ratified in 1943); OCGA §§ 20-3-21 (establishing how the Board shall be constituted); 20-3-31 (establishing

general powers of the Board); 20-3-51 (“The government, control, and

management of the university system and all of its institutions shall be vested

in the board of regents.”); Bd. of Regents of the Univ. Sys. of Georgia v. Doe, 278 Ga. App. 878, 885 (2) (a) (630 SE2d 85) (2006) (“In managing its member

institutions, the Board’s powers are plenary, untrammeled except by such

restraints of law as are directly expressed, or necessarily implied. Under the

powers granted, it becomes necessary to look for limitations, rather than for

authority to do specific acts. Limited only by their proper discretion and by the

5

To promote its educational mission and to ensure a safe learning,

working, and research environment, the Board has prohibited guns

within the USG since at least as far back as 1810. The Georgia Code

previously mirrored the USG’s no-guns policy, specifically, by

providing in OCGA § 16-11-127.1 that university campuses were

“school safety zones” where carrying or possessing a weapon,

including a firearm, triggered criminal penalties. 5 More recently, the

General Assembly declared “that the regulation of firearms and

other weapons is properly an issue of general, state-wide concern”

and prohibited counties and cities from regulating in any manner

the possession or carrying of firearms. OCGA § 16-11-173 (a), (b) (1)

Constitution and law of this State, they may exercise any power usually

granted to such corporations.” (citation and punctuation omitted)).

5 See Ga. Const. of 1983, Art. I, § I, Par. VIII (“The right of the people to

keep and bear arms shall not be infringed, but the General Assembly shall

have power to prescribe the manner in which arms may be borne.”); Ga. L.

1994, p. 1015, § 4 (adding public or private technical schools, vocational

schools, colleges, universities, and other institutions of postsecondary

education to the definition of “school safety zone,” where, unless otherwise

provided, it was a felony to carry any weapon while within a school safety zone

or at a school building, school function, or school property or on transportation

furnished by the school); see also Ga. L. 2010, p. 963, § 1-4 (reducing the

criminal penalty for weapons carry license holders).

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(2005).6 In 2014, the General Assembly greatly expanded the areas

where licensed gun owners could take their weapons. 7 The General

Assembly also added state authorities, including any “board,” to

those entities expressly prohibited from regulating the possession or

carrying of firearms or other weapons. 8 At that time, carrying

weapons was still restricted on college campuses under the statutes

regulating “school safety zones.”9

The complaint also shows that, after years of opposition by the

Board and USG institution leaders to proposed “campus carry”

legislation, the General Assembly in 2017 amended the definition of

“school safety zone” to remove the criminal penalties for carrying

weapons on college campuses, with several exceptions. See Ga. L.

6 See Ga. L. 2005, p. 613, § 1.

7 See OCGA § 16-11-127 (c) (2014) (Generally, license holders “shall be

authorized to carry a weapon . . . in every location in this state,” except as

limited by statute or on private property per the property owner’s policy.); Ga.

L. 2014, p. 599, § 1-5.

8 See OCGA § 16-11-173 (b) (1) (2014); Ga. L. 2014, p. 599, § 1-11.

9 See OCGA §§ 16-11-127.1 (a) (3) (B) (2014) (defining property owned or

leased by “[a]ny public or private technical school, vocational school, college,

university, or other institution of postsecondary education” as a school safety

zone); 16-11-127.1 (b) (1) (2014) (making it unlawful to carry weapons in school

safety zones).

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2017, p. 341, § 1 (HB 280).10 In the absence of the statutory provision

10In pertinent part, OCGA § 16-11-127.1 (c) (2017) as amended provided:

The provisions of this Code section [making it unlawful for

any person to carry or possess any weapon while within a school

safety zone, at a school function, or on a bus or other transportation

furnished by a school] shall not apply to: . . .

(20) (A) Any weapons carry license holder when

he or she is in any building or on real property owned

by or leased to any public technical school, vocational

school, college, or university, or other public

institution of postsecondary education; provided,

however, that such exception shall:

(i) Not apply to buildings or property

used for athletic sporting events or

student housing, including, but not

limited to, fraternity and sorority houses;

(ii) Not apply to any preschool or

childcare space located within such

buildings or real property;

(iii) Not apply to any room or space

being used for classes related to a college

and career academy or other specialized

school as provided for under Code Section

20-4-37;

(iv) Not apply to any room or space

being used for classes in which high school

students are enrolled through a dual

enrollment program, including, but not

limited to, classes related to the “Move on

When Ready Act” as provided for under

Code Section 20-2-161.3;

(v) Not apply to faculty, staff, or

administrative offices or rooms where

disciplinary proceedings are conducted;

(vi) Only apply to the carrying of

handguns which a licensee is licensed to

carry pursuant to subsection (e) of Code

8

Section 16-11-126 and pursuant to Code

Section 16-11-129; and

(vii) Only apply to the carrying of

handguns which are concealed.

(B) Any weapons carry license holder who

carries a handgun in a manner or in a building,

property, room, or space in violation of this paragraph

shall be guilty of a misdemeanor; provided, however,

that for a conviction of a first offense, such weapons

carry license holder shall be punished by a fine of

$25.00 and not be sentenced to serve any term of

confinement.

(C) As used in this paragraph, the term:

(i) “Concealed” means carried in

such a fashion that does not actively solicit

the attention of others and is not

prominently, openly, and intentionally

displayed except for purposes of defense of

self or others. Such term shall include, but

not be limited to, carrying on one’s person

while such handgun is substantially, but

not necessarily completely, covered by an

article of clothing which is worn by such

person, carrying within a bag of a

nondescript nature which is being carried

about by such person, or carrying in any

other fashion as to not be clearly

discernible by the passive observation of

others.

(ii) “Preschool or childcare space”

means any room or continuous collection

of rooms or any enclosed outdoor facilities

which are separated from other spaces by

an electronic mechanism or humanstaffed point of controlled access and

designated for the provision of preschool

or childcare services, including, but not

limited to, preschool or childcare services

licensed or regulated under Article 1 of

9

that criminalized carrying guns on university and college campuses,

as it existed prior to the 2017 amendment (HB 280), OCGA §§ 16-11-127, 16-11-127.1, and 16-11-173 operate together to require that

guns be allowed on USG campuses in ways that the professors allege

are contrary to “the Board of Regents’ and University System

institutions’ own duly adopted policies reflecting their independent

judgment.” After the governor approved HB 280, the Board’s

chancellor provided guidance to USG institutions to “implement the

law as written” and called for each institution to “review its campus

conduct and weapons policies to ensure that they comply with these

changes to the law.” The Board of Regents then amended its Policy

Manual and adopted a weapons policy, applicable to all USG

institutions, that largely mirrored the 2017 statutory amendments,

including the definitions of “weapon” and “concealed” and the

authority of weapons carry license holders to carry handguns on

USG campuses, subject to the same exceptions set out in the 2017

Chapter 1A of Title 20.

See also Ga. L. 2022, p. 74, §§ 6; 7 (replacing “license holder” with “lawful

weapons carrier” in OCGA §§ 16-11-127 (c) and 16-11-127.1).

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amendment to OCGA § 16-11-127.1. In the complaint, the professors

articulated in detail reasons they believe that the revised policy

regarding the carrying of weapons on USG campuses, following the

2017 statutory amendments, greatly increases the risk of injury and

death to themselves, their students, and other persons on USG

campuses, and significantly impairs their ability to fulfill their role

in the educational mission of the USG.

The crux of the professors’ constitutional challenge to the 2017

amendment is that, in adopting the amendment, the General

Assembly, to the detriment of the USG’s educational mission,

“usurp[ed] the Board of Regents’ constitutionally conferred,

exclusive authority over the government, control, and management”

of the USG, specifically, the Board’s “authority to regulate, in its

independent judgment, guns on college campuses.” The professors

alleged that they are injured by what they deem a “separation-ofpowers violation.” 11 They argue that the trial court erred to the

See Ga. Const. of 1983, Art. I, Sec. II, Par. III (“The legislative, judicial,

11

and executive powers shall remain separate and distinct[.]”).

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extent that it dismissed their claim as moot, arguing that, “[a]s a

matter of law, a separation-of-powers violation is not mooted by the

fact that the encroached-upon entity has acquiesced — or even

affirmatively approved of — the encroachment.”

The professors acknowledge the absence of Georgia precedent

for this principle and cite as persuasive authority several United

States Supreme Court cases. But even assuming we found these

federal cases persuasive, they do not lead to a conclusion in this case

that the professors’ claims are not moot. These federal cases share a

common thread that does not run through this case. In those cases,

a legislative act challenged on separation-of-powers or Tenth

Amendment grounds directly caused the harm complained of, such

that some indication of agreement with the legislative act by the

allegedly-encroached-upon entity could not moot a challenge to the

legislation. 12 Here, in contrast, the Board formally took its own

12 See Selia Law LLC v. Consumer Financial Protection Bureau, 140 SCt

2183, 2192, 2196 (207 LE2d 494) (2020) (concluding that the structure of a new

regulatory agency created by Congress violated separation-of-powers

principles by insulating the director from removal by the President; rejecting

12

action to adopt a particular policy, and it is this policy, not any

legislation, that is causing the state of affairs about which the

the argument that a litigant challenging an action by the agency must show

that the act would not have been taken if the director had been subject to

presidential control); Free Enterprise Fund v. Public Co. Accounting Oversight

Bd., 561 U.S. 477, 497-498 (130 SCt 3138, 177 LE2d 706) (2010) (concluding

that Congress’s creation of federal accounting oversight board that was not

subject to presidential control violated separation-of-powers principles,

notwithstanding that the President signed the act creating the board without

expressing any separation-of-powers concerns); New York v. United States, 505

U.S. 144, 177, 180-183 (112 SCt 2408, 120 LE2d 120) (1992) (concluding that

congressional act regarding states’ disposal of radioactive waste violated Tenth

Amendment, notwithstanding that public officials from the state challenging

the law “lent their support to the Act’s enactment”); Metro. Washington

Airports Auth. v. Citizens for Abatement of Aircraft Noise, Inc., 501 U.S. 252,

264-270, 276-277 & n.13 (111 SCt 2298, 115 LE2d 236 (1991) (concluding that

a congressional act conditioning the transfer of operating control of certain

airports on the creation of an oversight board comprised of members of

Congress violated separation-of-powers principles notwithstanding that the

board was established by the bylaws of airports authority that was created by

legislation enacted by Virginia and the District of Columbia; the challenge to

the oversight board’s veto power was ripe even if that power had not yet been

exercised to challengers’ detriment); see also Natl. Labor Relations Bd. v.

Canning, 573 U.S. 513, 570-572 (134 SCt 2550, 189 LE2d 538) (2014) (Scalia,

J., concurring) (rejecting the Court’s reliance on the Senate’s historical failure to counter “with sufficient vigor” presidents’ reliance on the Recess

Appointments Clause to fill vacancies that initially occur before, but continue

to exist during, a recess of the Senate; citing precedent that, “[s]ince the

separation of powers exists for the protection of individual liberty, its vitality does not depend on whether the encroached-upon branch approves the

encroachment” (citations and punctuation omitted)); Glidden Co. v. Zdanok,

370 U.S. 530, 532-533 (82 SCt 1459, 8 LE2d 671) (1962) (plurality opinion)

(considering an argument that litigants were denied the protection guaranteed

by Article III of having judges with tenure and compensation preside over their

cases, notwithstanding that the Chief Justice of the United States, pursuant

to statute, had designated the judges to preside over the cases).

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professors complain.

In determining that this action by the Board moots the

professors’ challenge to the 2017 amendment, we do not concern

ourselves with why the Board took this action. We do not look behind

the exercise of government power to determine the subjective

reasons — legal, political, or otherwise — for a particular action, so

long as the action was within the government actor’s authority.

Indeed, it is difficult to conceive of a significant executive- or

legislative-branch action where the knowledge of the positions of

various other governmental actors will not factor into the decision.

Here, what matters is not why the Board adopted the policy in

question, but merely that it did do so. Granting the only relief the

professors seek — a declaration that the 2017 amendment to OCGA

§ 16-11-127.1 constituted a separation-of-powers violation — would

not eliminate the harm of which the professors complain, because it

would not eliminate the immediate source of that alleged harm —

the weapons policy adopted by the Board. That this sought-after

relief would not redress the professors’ stated grievance means that

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this case is moot. The trial court thus did not err in dismissing the

professors’ complaint. See Berzett, 301 Ga. at 394-396; Baker, 271

Ga. at 214-215 (1); Fourth St. Baptist Church, 253 Ga. at 369 (1).

Judgment affirmed. All the Justices concur, except Warren,

McMillian, and Pinson, JJ., disqualified.

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