Matthew Moore sought to modify child custody after his teenage child initially elected to live with him. He later paid $16,400 in child-support arrears and decided to dismiss the custody petition after the child changed her mind. The trial court awarded Moore’s former wife $4,000 in attorney fees, stating that Moore had been held in contempt and had unreasonably delayed the case. The Georgia Court of Appeals vacated the award. The record showed that the contempt motion had not been adjudicated, so the trial court could not rely on a nonexistent contempt finding. The court also held that the order did not contain the factual findings needed to support fees for unreasonable delay under Georgia’s litigation-sanctions statute, and that the award was not apportioned to sanctionable conduct. Although another custody-fee statute might apply, the appellate court remanded for the trial court to reconsider the award under the correct legal basis and with sufficient findings.