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Janine A. Landryv.Daniel Walsh

CourtCourt of Appeals of Georgia
Docket No.A17A0449
DecidedMay 25, 2017
Reporter300 Ga. App. 647
JudgesCourt of Appeals of Georgia
Tags
CivilFamily LawEvidenceCivil ProcedureDue ProcessReversalRemand
Case Summary

Janine Landry and Daniel Walsh brought cross-appeals from rulings in their custody dispute. Landry challenged the exclusion of testimony from the children’s treating psychiatrist and one of two attorney-fee awards to Walsh, while Walsh challenged the other fee award. The Georgia Court of Appeals affirmed the evidentiary ruling, concluding that the psychiatrist’s communications with the children were protected and that the record did not establish a basis to admit the testimony. It reversed both attorney-fee awards because the trial court did not make the findings required by the governing statutes and did not adequately connect the awards to the conduct at issue. The court remanded for further proceedings on fees while leaving the custody ruling and evidentiary ruling intact.

Opinion

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