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Scott Cockerhamv.Barbara Cockerham

CourtCourt of Appeals of Georgia
Docket No.A21A0553
DecidedJune 18, 2021
Reporter159 Ga. App. 624
JudgesCourt of Appeals of Georgia
Tags
CivilFamily LawChild CustodyCivil ProcedureEvidenceRemandVacatur
Case Summary

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.

Opinion

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