Georgia Farm Bureau Mutual Insurance v. Joiner International, Inc.

In my opinion, there is no real or rational reason to overrule Big Bear Ranches v. Ga. Farm &c. Ins. Co., 169 Ga. App. 307 (312 SE2d 378) (1983), as the two cases differ sufficiently in their facts to warrant a result in the instant case different from that in Big Bear Ranches.

The word “includes” has two distinct meanings. The first, and more usual, meaning is that something is added to the preceding language, either by defining/specifying the preceding term or by adding something not necessarily implied therein; it is thus ordinarily a term of enlargement, and is so used in the instant case.…