Georgia Lottery Corporation v. Patel.

Because I believe that under governing Supreme Court precedent, the scratch off lottery ticket that Patel presented is at most evidence of an implied contract, and an express written contract is required to waive GLC's sovereign immunity, I must respectfully dissent.

The Georgia Constitution provides:

The state's defense of sovereign immunity is hereby waived as to any action ex contractu for the breach of any written contract now existing or hereafter entered into by the state or its departments and agencies.

Ga. Const. of 1983, Art. I, Sec. II, Par. IX (c). Recently, in Ga. Dept. of Labor v.…