Quiet title judgment may be obtained by default after service by publication
When a defendant in a quiet title action is served by publication, their deadline to respond is 60 days after the Order for service, and they are in default if they do not then answer. Once 15 days to open that default has expired, then the plaintiff is entitled to seek a default judgment.
In the case of Patel v. Patel, 802 S.E.2d 871 (Ga. App. 2017) the Court of Appeals upheld the use of this procedure in a conventional quiet title action. The relevant holding is as follows: