Waiver of sovereign immunity in Georgia is limited at the county level to the limit of insurance for claims of injury related to use of a motor vehicle. Cases over the past twenty five years have wrestled with what actions involve “use” of a motor vehicle and what qualifies as a “motor vehicle.” The Georgia Court of Appeals recently penned a twist on this analysis and reversed the denial of a judgment on the pleadings to Columbus Consolidated Government (“Columbus”). In October 2011, an inmate, Franklin Woody (“Woody”), was welding a dump truck which was not in use, when the sparks caught his jumpsuit on fire. Woody was burned and brought suit against Columbus for his injuries. As refer