After the children’s mother died during divorce proceedings, a Georgia superior court awarded permanent custody of three children to their maternal grandparents. The father appealed, challenging the emergency order, jurisdiction, service, and the final custody proceedings. The Court of Appeals of Georgia reversed and remanded. It held that the trial court improperly considered evidence outside the final hearing without giving the parties notice and an opportunity to respond, and that the resulting custody determination could not stand. The court directed further proceedings consistent with the opinion.