After a divorce decree required Donald Belcher to pay monthly alimony, he stopped payment and demanded that his former spouse provide proof that she was still alive. He then filed a declaratory-judgment action seeking an order requiring her to verify her continuing health status. The trial court dismissed that action, and awarded Sarah Belcher attorney fees. In an earlier appeal, the Supreme Court of Georgia vacated the fee award and required a proper order under the attorney-fee statute. On remand, the trial court awarded $2,500 without identifying the statutory subsection or specifying the sanctionable conduct. The Georgia Court of Appeals affirmed that attorney fees were appropriate because the declaratory action presented no justiciable issue the court could reasonably accept. But it vacated the amount and remanded. An award under the applicable subsection must identify the conduct that caused the fees and explain why the particular amount is reasonable; a lump-sum, unapportioned award is not permitted. The trial court had to make those findings on remand.