Dwayne Woodson and Maxine Lino, unmarried biological parents of a child born in 2008, litigated custody after Lino moved from Georgia to New York. The trial court legitimated Woodson, awarded joint legal custody with Lino as the primary physical custodian, required Lino to return to Georgia, and ordered Woodson to pay relocation expenses and child support. The Georgia Court of Appeals upheld the custody determination but vacated the portion requiring Woodson to pay the specified relocation costs. Georgia’s child-support guidelines permit deviations for certain extraordinary expenses, but a deviation requires written findings of fact and application of the child’s best-interest standard. The trial court’s order expressly stated that no deviation applied, even though it assessed the mother’s security deposit, housing costs, airfare, and lodging against the father. Without the required findings, the appellate court could not determine whether that portion of the award was lawful. It affirmed the custody ruling, vacated the relocation-cost award, and remanded for reconsideration.