Matthew Wilson and Debra Perkins shared custody of their child after divorcing. The trial court later modified custody in Perkins’s favor after evidence concerning bruising on the child and Wilson’s related criminal charges, and it awarded Perkins attorney fees. Wilson appealed the modification, the admission of his nolo contendere plea, and the fee award. The Georgia Court of Appeals held that the custody modification ruling could not stand on the record presented and that the fee award tied to the modification petition had to be reconsidered. The court vacated the fee award and remanded for further proceedings on that issue, while reversing the custody modification in part. The opinion treated the remaining evidentiary and jury-instruction arguments as unnecessary to resolve after the custody ruling. The judgment was therefore reversed in part, vacated in part, and remanded with direction.