Diana Marie Pascal petitioned to modify custody, while her former husband counterclaimed to modify child support. At trial, the father also sought primary physical custody, and the court awarded it to him. The Court of Appeals of Georgia vacated the order and remanded for a hearing limited to the mother’s petition. The court held that the father’s request for a custody modification was not properly before the trial court because it was not included in his counterclaim. The court therefore could not consider the father’s request or grant relief on it, and it did not reach the mother’s alternative challenges to the evidence or the best-interests ruling.