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In The Interest Of S. W., A Child (Mother)

CourtCourt of Appeals of Georgia
Docket No.A22A0515
DecidedApril 18, 2022
Reporter353 Ga. App. 855
JudgesCourt of Appeals of Georgia
Tags
CivilFamily LawChild CustodyDue ProcessCivil ProcedureVacaturRemand
Case Summary

The Columbia County Department of Family and Children Services took the child into custody after the death of her two-year-old sibling and allegations of inadequate supervision. The juvenile court found the child dependent, placed her with her father, and later entered a temporary visitation order while addressing custody and reunification. The mother appealed. The Court of Appeals of Georgia held that the juvenile court had not made the specific factual findings required to support its dependency disposition and had improperly treated dependency issues as an ordinary custody determination. Because the child’s current circumstances and the statutory disposition factors had not been adequately addressed, the appellate court vacated both the temporary visitation order and the earlier custody order. It remanded for an evidentiary hearing focused on the child’s current status and for a new disposition containing appropriate findings of fact and legal conclusions.

Opinion

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