Scott Cockerhamv.Barbara Cockerham
Scott Cockerham sought equal parenting time after a divorce decree gave the parents joint custody with the mother as primary physical custodian. The trial court modified his parenting schedule, awarded the mother attorney fees, and required him to pay the outstanding guardian-ad-litem balance. On appeal, Cockerham challenged the absence of findings and conclusions, continuances, the guardian ad litem’s appointment and conduct, constitutional issues, and alleged hearsay. The Court of Appeals of Georgia vacated the portion of the order modifying parenting time and remanded for further consideration, while affirming the fee awards. It held that the constitutional claims were not preserved, the hearsay objection was not made on that ground, and the father showed no reversible prejudice from the guardian ad litem’s conduct. The ruling illustrates the preservation limits governing appellate review of custody litigation.
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