A juvenile court found several children dependent and imposed a case plan requiring supervised contact with their father after the Department of Family and Children Services alleged a history of domestic violence. The father appealed, arguing that the evidence did not support a dependency finding as to him. The Georgia Court of Appeals held that the mother’s stipulation in her separate case did not establish facts in the father’s case. The stipulation largely accepted legal conclusions about the allegations but did not identify specific incidents or prove that the children had witnessed the alleged violence. Testimony from the mother and an investigating detective likewise failed to show that the central incident occurred in the children’s presence. Because the record did not contain clear and convincing evidence of abuse sufficient to support dependency as to the father, the court reversed the juvenile court’s finding. It did not reach the father’s separate challenge to supervised visitation.