section 19-6-2 award of attorney fees (Georgia) · Go Syfert
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section 19-6-2 award of attorney fees in Georgia

55 Georgia opinions name it 2 courts 1996–2026 12 in the last five years

The cases below were cited by Georgia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (66)

CaseFollowedCited
Cason v. Casongreen
ga · 2006 · cited in 9 Georgia opinions naming this issue, 2017–2026
2 sentences

2026In divorce and alimony cases, a trial court may award attorney fees under OCGA § 19-6-2(a)(1) after “consider[ing] the financial circumstances of both parties.” In this regard, an OCGA § 19-6-2 award is not premised on a party’s wrongdoing; rather, “it is to be made with the purpose of ensuring effective representation of both spouses in an action arising out of a divorce.” Cason v. Cason, 281 Ga. 296 , 299–300(3) ( 637 SE2d 716 ) (2006).

2026In divorce and alimony cases, a trial court may award attorney fees under OCGA § 19-6-2(a)(1) after “consider[ing] the financial circumstances of both parties.” In this regard, an OCGA § 19-6-2 award is not premised on a party’s wrongdoing; rather, “it is to be made with the purpose of ensuring effective representation of both spouses in an action arising out of a divorce.” Cason v. Cason, 281 Ga. 296 , 299–300(3) ( 637 SE2d 716 ) (2006).

79
Moon v. Moongreen
ga · 2003 · cited in 8 Georgia opinions naming this issue, 2004–2025
2 sentences

2025“The purpose of an award of attorney fees pursuant to § 19-6-2 is to ensure effective representation of both spouses so that all 10 issues can be fully and fairly resolved.” (Citation and punctuation omitted.) Moon, 277 Ga. at 379 (6).

2024See also Williams v. Cooper, 280 Ga. 145, 147 (1) ( 625 SE2d 754 ) (2006) (“an award under OCGA § 19-6-2 depends on the financial circumstances of the parties, not their wrongdoing”); Moon v. Moon, 277 Ga. 375, 378 (6), n.4 ( 589 SE2d 76 ) (2003) (given 4 the purpose of a fees award under OCGA § 19-6-2, such an award cannot be “predicated upon a finding of misconduct of a party”).

68
Amoakuh v. Issakagreen
ga · 2016 · cited in 5 Georgia opinions naming this issue, 2017–2026
2 sentences

2021In divorce and alimony cases, a trial court may award attorney fees under OCGA § 19-6-2 (a) (1) after “consider[ing] the financial circumstances of both parties.” In this regard, such an award is not premised on a party’s wrongdoing; 11 See Daniel v. Daniel, 358 Ga. App. 880 , 886 (1) (a) ( 856 SE2d 452 ) (2021) (“[I]t was for the trial court to determine whether a party’s own representations regarding her income were credible. . . .”). 12 Cf. Dodson v. Walraven, 318 Ga. App. 586, 588-589 (1) ( 734 SE2d 428 ) (2012) (imputing income based on family generosity was error due to lack of evidence)

2021In divorce and alimony cases, a trial court may award attorney fees under OCGA § 19-6-2 (a) (1) after “consider[ing] the financial circumstances of both parties.” In this regard, such an award is not premised on a party’s wrongdoing; 11 See Daniel v. Daniel, 358 Ga. App. 880 , 886 (1) (a) ( 856 SE2d 452 ) (2021) (“[I]t was for the trial court to determine whether a party’s own representations regarding her income were credible. . . .”). 12 Cf. Dodson v. Walraven, 318 Ga. App. 586, 588-589 (1) ( 734 SE2d 428 ) (2012) (imputing income based on family generosity was error due to lack of evidence)

55
Hoard v. Beveridgegreen
ga · 2016 · cited in 5 Georgia opinions naming this issue, 2017–2023
2 sentences

2019Hoard v. Beveridge, 298 Ga. 728, 731 (2) ( 783 SE2d 629 ) (2016) (award under OCGA § 19-6-2 upheld where record and fee hearing transcript show that the trial court considered parties’ relative financial positions); Reid v. Reid, 348 Ga. App. 550, 552-53 (1) ( 823 SE2d 860 ) (2019) (attorney fee award under OCGA § 19-6-2 affirmed where trial court’s order contains sufficient findings to show that it considered the relative finances of each party); cf. Amoakuh v. Issaka, 299 Ga. 132, 134 (3) ( 786 SE2d 678 ) (2016) (attorney fees order awarding fees under OCGA § 19-6-2 vacated and remanded wher

2019Hoard v. Beveridge, 298 Ga. 728, 731 (2) ( 783 SE2d 629 ) (2016) (award under OCGA § 19-6-2 upheld where record and fee hearing transcript show that the trial court considered parties’ relative financial positions); Reid v. Reid, 348 Ga. App. 550, 552-53 (1) ( 823 SE2d 860 ) (2019) (attorney fee award under OCGA § 19-6-2 affirmed where trial court’s order contains sufficient findings to show that it considered the relative finances of each party); cf. Amoakuh v. Issaka, 299 Ga. 132, 134 (3) ( 786 SE2d 678 ) (2016) (attorney fees order awarding fees under OCGA § 19-6-2 vacated and remanded wher

55
Johnson v. Johnsongreen
ga · 2008 · cited in 5 Georgia opinions naming this issue, 2013–2019
2 sentences

2016Based on this record, we cannot say that the trial court abused its discretion in making its award which ensured effective representation of both spouses. 4 See Simmons, 288 Ga. at 673-674 (finding no abuse of discretion where record showed trial court considered the parties’ relative financial positions and granted fees to wife because she would be primary physical custodian); Patel v. Patel, 285 Ga. 391, 393 (4) ( 677 SE2d 114 ) (2009) (finding no abuse of discretion in trial court’s decision to deny wife’s claim for attorney fees under OCGA § 19-6-2 where the trial court found both parties

2016Based on this record, we cannot say that the trial court abused its discretion in making its award which ensured effective representation of both spouses. 4 See Simmons, 288 Ga. at 673-674 (finding no abuse of discretion where record showed trial court considered the parties’ relative financial positions and granted fees to wife because she would be primary physical custodian); Patel v. Patel, 285 Ga. 391, 393 (4) ( 677 SE2d 114 ) (2009) (finding no abuse of discretion in trial court’s decision to deny wife’s claim for attorney fees under OCGA § 19-6-2 where the trial court found both parties

55
Johnson v. Johnsongreen
ga · 1990 · cited in 6 Georgia opinions naming this issue, 1997–2026
2 sentences

2019The purpose of an award of attorney fees pursuant to OCGA § 19-6-2 is "to ensure effective representation of both spouses so that all issues can be fully and fairly resolved." (Citation omitted.) Johnson v. Johnson , 260 Ga. 443 , 444, 396 S.E.2d 234 (1990).

2019The purpose of an award of attorney fees pursuant to OCGA § 19-6-2 is "to ensure effective representation of both spouses so that all issues can be fully and fairly resolved." (Citation omitted.) Johnson v. Johnson , 260 Ga. 443 , 444, 396 S.E.2d 234 (1990).

46
Reid v. Reid.green
gactapp · 2019 · cited in 4 Georgia opinions naming this issue, 2019–2025
2 sentences

2019Hoard v. Beveridge, 298 Ga. 728, 731 (2) ( 783 SE2d 629 ) (2016) (award under OCGA § 19-6-2 upheld where record and fee hearing transcript show that the trial court considered parties’ relative financial positions); Reid v. Reid, 348 Ga. App. 550, 552-53 (1) ( 823 SE2d 860 ) (2019) (attorney fee award under OCGA § 19-6-2 affirmed where trial court’s order contains sufficient findings to show that it considered the relative finances of each party); cf. Amoakuh v. Issaka, 299 Ga. 132, 134 (3) ( 786 SE2d 678 ) (2016) (attorney fees order awarding fees under OCGA § 19-6-2 vacated and remanded wher

2019Hoard v. Beveridge, 298 Ga. 728, 731 (2) ( 783 SE2d 629 ) (2016) (award under OCGA § 19-6-2 upheld where record and fee hearing transcript show that the trial court considered parties’ relative financial positions); Reid v. Reid, 348 Ga. App. 550, 552-53 (1) ( 823 SE2d 860 ) (2019) (attorney fee award under OCGA § 19-6-2 affirmed where trial court’s order contains sufficient findings to show that it considered the relative finances of each party); cf. Amoakuh v. Issaka, 299 Ga. 132, 134 (3) ( 786 SE2d 678 ) (2016) (attorney fees order awarding fees under OCGA § 19-6-2 vacated and remanded wher

44
McGahee v. Rogersgreen
ga · 2006 · cited in 4 Georgia opinions naming this issue, 2013–2023
2 sentences

2023See, e.g., OCGA § 9-15-14 (a) (“In any civil action in any court of record of this state, reasonable and necessary attorney’s fees and expenses of litigation shall be awarded to any party against whom another party has asserted a claim,” etc. (emphasis supplied)); McGahee v. Rogers, 280 Ga. 750, 754 (2) ( 632 SE2d 657 ) (2006) (“[A]n award of attorney’s fees under OCGA § 19-6-2 in this case would require a determination whether McGahee violated the divorce decree.” (citation and punctuation omitted; emphasis supplied)); L.S.

2023See, e.g., OCGA § 9-15-14 (a) (“In any civil action in any court of record of this state, reasonable and necessary attorney’s fees and expenses of litigation shall be awarded to any party against whom another party has asserted a claim,” etc. (emphasis supplied)); McGahee v. Rogers, 280 Ga. 750, 754 (2) ( 632 SE2d 657 ) (2006) (“[A]n award of attorney’s fees under OCGA § 19-6-2 in this case would require a determination whether McGahee violated the divorce decree.” (citation and punctuation omitted; emphasis supplied)); L.S.

44
Vakharwala v. Vakharwalagreen
ga · 2017 · cited in 3 Georgia opinions naming this issue, 2019–2019
2 sentences

2019See Vakharwala, 301 Ga. at 254-255 (1) (b). 4 The Wife’s allegations regarding the Husband’s misconduct did not support a claim for attorney fees under OCGA § 19-6-2.

2019“Attorney fees . . . awarded to a spouse pursuant to OCGA § 19-6-2 . . . are considered to be a part of alimony.” Vakharwala v. Vakharwala, 301 Ga. 251, 254 (1) (b) ( 799 SE2d 797 ) (2017) (citations omitted). 9 The parties dispute whether the terms of their settlement agreement, which the trial court incorporated into the final divorce decree, permit the recovery of attorney fees under OCGA § 19-6-2.

33
Horn v. Shepherdgreen
ga · 2012 · cited in 3 Georgia opinions naming this issue, 2013–2013
2 sentences

2013OCGA § 19-6-2 (a) provides that attorney fees in a contempt of court action arising from child custody and visitation rights provisions of a divorce decree are “[w]ithin the sound discretion of the court, except that the court shall consider the financial circumstances of both parties as a part of its determination of the amount of attorney’s fees, if any, to be allowed against either party[.]” “We have held that a trial court may award or decline to award attorney fees sought under OCGA § 19-6-2 (a) (1) based on evidence of the financial circumstances of the parties presented at trial and bas

2013OCGA § 19-6-2 (a) provides that attorney fees in a contempt of court action arising from child custody and visitation rights provisions of a divorce decree are “[w]ithin the sound discretion of the court, except that the court shall consider the financial circumstances of both parties as a part of its determination of the amount of attorney’s fees, if any, to be allowed against either party[.]” “We have held that a trial court may award or decline to award attorney fees sought under OCGA § 19-6-2 (a) (1) based on evidence of the financial circumstances of the parties presented at trial and bas

23
Thrasher-Starobin v. Starobingreen
ga · 2016 · cited in 2 Georgia opinions naming this issue, 2021–2026
2 sentences

2021In divorce and alimony cases, a trial court may award attorney fees under OCGA § 19-6-2 (a) (1) after “consider[ing] the financial circumstances of both parties.” In this regard, such an award is not premised on a party’s wrongdoing; 11 See Daniel v. Daniel, 358 Ga. App. 880 , 886 (1) (a) ( 856 SE2d 452 ) (2021) (“[I]t was for the trial court to determine whether a party’s own representations regarding her income were credible. . . .”). 12 Cf. Dodson v. Walraven, 318 Ga. App. 586, 588-589 (1) ( 734 SE2d 428 ) (2012) (imputing income based on family generosity was error due to lack of evidence)

2021In divorce and alimony cases, a trial court may award attorney fees under OCGA § 19-6-2 (a) (1) after “consider[ing] the financial circumstances of both parties.” In this regard, such an award is not premised on a party’s wrongdoing; 11 See Daniel v. Daniel, 358 Ga. App. 880 , 886 (1) (a) ( 856 SE2d 452 ) (2021) (“[I]t was for the trial court to determine whether a party’s own representations regarding her income were credible. . . .”). 12 Cf. Dodson v. Walraven, 318 Ga. App. 586, 588-589 (1) ( 734 SE2d 428 ) (2012) (imputing income based on family generosity was error due to lack of evidence)

22
Williams v. Coopergreen
ga · 2006 · cited in 2 Georgia opinions naming this issue, 2010–2024
2 sentences

2024See also Williams v. Cooper, 280 Ga. 145, 147 (1) ( 625 SE2d 754 ) (2006) (“an award under OCGA § 19-6-2 depends on the financial circumstances of the parties, not their wrongdoing”); Moon v. Moon, 277 Ga. 375, 378 (6), n.4 ( 589 SE2d 76 ) (2003) (given 4 the purpose of a fees award under OCGA § 19-6-2, such an award cannot be “predicated upon a finding of misconduct of a party”).

2024See also Williams v. Cooper, 280 Ga. 145, 147 (1) ( 625 SE2d 754 ) (2006) (“an award under OCGA § 19-6-2 depends on the financial circumstances of the parties, not their wrongdoing”); Moon v. Moon, 277 Ga. 375, 378 (6), n.4 ( 589 SE2d 76 ) (2003) (given 4 the purpose of a fees award under OCGA § 19-6-2, such an award cannot be “predicated upon a finding of misconduct of a party”).

22
L. S. Land Co. v. Burnsgreen
ga · 2002 · cited in 2 Georgia opinions naming this issue, 2023–2023
2 sentences

2023Land Co. v. Burns, 275 Ga. 454, 457 (3) ( 569 SE2d 527 ) (2002) (“[W]e cannot hold as a matter of law that attorney’s fees in this reformation case were not authorized under [OCGA] § 13-6-11.”).

2023Land Co. v. Burns, 275 Ga. 454, 457 (3) ( 569 SE2d 527 ) (2002) (“[W]e cannot hold as a matter of law that attorney’s fees in this reformation case were not authorized under [OCGA] § 13-6-11.”).

22
Duncan v. Duncangreen
ga · 1993 · cited in 2 Georgia opinions naming this issue, 2010–2020
2 sentences

2020See Klardie v. Klardie, 287 Ga. 499, 503 (3) ( 697 SE2d 207 ) (2010) (“In certain domestic cases, earning capacity is an appropriate means to determine an award of attorney fees pursuant to OCGA § 19-6-2.”); Wier 14 v. Wier, 287 Ga. 443, 444 (4) ( 696 SE2d 658 ) (2010) (trier of fact “may consider assets and earning capacity, in addition to income, in fixing the amount of alimony”); Taylor v. Taylor, 283 Ga. 63, 64 (1) ( 656 SE2d 828 ) (2008) (affirming trial court’s decision as to how to equitably distribute retirement accounts based on, among other things, evidence of the wife’s earning pote

2010Duncan v. Duncan, 262 Ga. 872, 873 (1), 426 S.E.2d 857 (1993).

22
Kautter v. Kauttergreen
ga · 2009 · cited in 2 Georgia opinions naming this issue, 2020–2020
2 sentences

2020See, e.g., Kautter, 286 Ga. at 19-20 (4) (c) (noting that OCGA § 19-6-2 authorizes an award of attorney fees “at any time during the pendency of the litigation”).

2020See, e.g., Kautter, 286 Ga. at 19-20 (4) (c) (noting that OCGA § 19-6-2 authorizes an award of attorney fees “at any time during the pendency of the litigation”).

22
Langley v. Langleygreen
ga · 2005 · cited in 2 Georgia opinions naming this issue, 2017–2017
2 sentences

2017See Langley v. Langley, 279 Ga. 374 (1) ( 613 SE2d 614 ) (2005).

2017See Langley v. Langley, 279 Ga. 374 (1) ( 613 SE2d 614 ) (2005).

22
Ward v. Wardgreen
ga · 2011 · cited in 2 Georgia opinions naming this issue, 2014–2015
2 sentences

2014But the father argues in his appellate brief that he was entitled to attorney fees pursuant to OCGA § 19-6- 8 Nesbit v. Nesbit, 295 Ga. App. 763 ( 673 SE2d 272 ) (2009) (citation and punctuation omitted). 9 Ward v. Ward, 289 Ga. 250, 251-252 (2) ( 710 SE2d 555 ) (2011) (citation and punctuation omitted); Woods v. Hall, 315 Ga. App. 93, 97 (2) ( 726 SE2d 596 ) (2012). 8 2.10 Even if this court presumes that the trial court denied the father’s request for attorney fees pursuant to OCGA § 19-6-2,11 the father has shown no abuse of discretion.

2014But the father argues in his appellate brief that he was entitled to attorney fees pursuant to OCGA § 19-6- 8 Nesbit v. Nesbit, 295 Ga. App. 763 ( 673 SE2d 272 ) (2009) (citation and punctuation omitted). 9 Ward v. Ward, 289 Ga. 250, 251-252 (2) ( 710 SE2d 555 ) (2011) (citation and punctuation omitted); Woods v. Hall, 315 Ga. App. 93, 97 (2) ( 726 SE2d 596 ) (2012). 8 2.10 Even if this court presumes that the trial court denied the father’s request for attorney fees pursuant to OCGA § 19-6-2,11 the father has shown no abuse of discretion.

22
Findley v. Findleygreen
ga · 2006 · cited in 2 Georgia opinions naming this issue, 2008–2014
2 sentences

2014The purpose of an award of attorney fees pursuant to OCGA § 19-6-2 is to “ensure effective representation of both spouses so that all issues can be fully and fairly resolved.”12 “[A]n award of attorney fees pursuant to [OCGA] § 19-6-2 is not predicated upon a finding of misconduct of a party.”13 10 See Hunter v. Hunter, 289 Ga. 9, 10 (2) ( 709 SE2d 263 ) (2011) (appellate court presumed that attorney fees award was made pursuant to OCGA § 19-6-2 where trial court’s order did not specify the statute pursuant to which it had considered an award of attorney fees, neither party sought attorney fee

2014The purpose of an award of attorney fees pursuant to OCGA § 19-6-2 is to “ensure effective representation of both spouses so that all issues can be fully and fairly resolved.”12 “[A]n award of attorney fees pursuant to [OCGA] § 19-6-2 is not predicated upon a finding of misconduct of a party.”13 10 See Hunter v. Hunter, 289 Ga. 9, 10 (2) ( 709 SE2d 263 ) (2011) (appellate court presumed that attorney fees award was made pursuant to OCGA § 19-6-2 where trial court’s order did not specify the statute pursuant to which it had considered an award of attorney fees, neither party sought attorney fee

22
Wood v. Woodgreen
ga · 2008 · cited in 2 Georgia opinions naming this issue, 2009–2014
2 sentences

2014The purpose of an award of attorney fees pursuant to OCGA § 19-6-2 is to “ensure effective representation of both spouses so that all issues can be fully and fairly resolved.”12 “[A]n award of attorney fees pursuant to [OCGA] § 19-6-2 is not predicated upon a finding of misconduct of a party.”13 10 See Hunter v. Hunter, 289 Ga. 9, 10 (2) ( 709 SE2d 263 ) (2011) (appellate court presumed that attorney fees award was made pursuant to OCGA § 19-6-2 where trial court’s order did not specify the statute pursuant to which it had considered an award of attorney fees, neither party sought attorney fee

2014The purpose of an award of attorney fees pursuant to OCGA § 19-6-2 is to “ensure effective representation of both spouses so that all issues can be fully and fairly resolved.”12 “[A]n award of attorney fees pursuant to [OCGA] § 19-6-2 is not predicated upon a finding of misconduct of a party.”13 10 See Hunter v. Hunter, 289 Ga. 9, 10 (2) ( 709 SE2d 263 ) (2011) (appellate court presumed that attorney fees award was made pursuant to OCGA § 19-6-2 where trial court’s order did not specify the statute pursuant to which it had considered an award of attorney fees, neither party sought attorney fee

22
Brochin v. Brochingreen
gactapp · 2008 · cited in 2 Georgia opinions naming this issue, 2013–2013
2 sentences

2013See Hammonds v. Parks, 319 Ga. App. at 795 (3) (Because the mother’s request for a change in custody was improper, the trial court erred in considering it, in ordering the father to produce documents in response to it, and in requiring the father to pay the mother’s attorney fees for his failure to produce the documents earlier.); see also McGahee v. Rogers, 280 Ga. 750, 754 (2) ( 632 SE2d 657 ) (2006) (An award of attorney fees under OCGA § 19-6-2 3 requires a valid determination that the mother was in contempt of the consent order.); Brochin v. Brochin, 294 Ga. App. 406, 407 (2) ( 669 SE2d 2

2013See Hammonds v. Parks, 319 Ga. App. at 795 (3) (Because the mother’s request for a change in custody was improper, the trial court erred in considering it, in ordering the father to produce documents in response to it, and in requiring the father to pay the mother’s attorney fees for his failure to produce the documents earlier.); see also McGahee v. Rogers, 280 Ga. 750, 754 (2) ( 632 SE2d 657 ) (2006) (An award of attorney fees under OCGA § 19-6-2 3 requires a valid determination that the mother was in contempt of the consent order.); Brochin v. Brochin, 294 Ga. App. 406, 407 (2) ( 669 SE2d 2

22
Ferguson v. City of Doravillegreen
gactapp · 1988 · cited in 2 Georgia opinions naming this issue, 2003–2009
2 sentences

2009The damages authorized by § 9-15-14 “are intended not merely to punish or deter litigation abuses but also to recompense litigants who are forced to expend their resources in contending with [abusive litigation].” Ferguson v. City of Doraville, 186 Ga. App. 430, 440 ( 367 SE2d 551 ) (1988), overruled on other grounds, Vogtle v. Coleman, 259 Ga. 115 ( 376 SE2d 861 ) (1989).

2009The damages authorized by § 9-15-14 “are intended not merely to punish or deter litigation abuses but also to recompense litigants who are forced to expend their resources in contending with [abusive litigation].” Ferguson v. City of Doraville, 186 Ga. App. 430, 440 ( 367 SE2d 551 ) (1988), overruled on other grounds, Vogtle v. Coleman, 259 Ga. 115 ( 376 SE2d 861 ) (1989).

22
Viskup v. Viskupgreen
ga · 2012 · cited in 2 Georgia opinions naming this issue, 2014–2019
2 sentences

2019OCGA § 19-6-2 (a) authorizes attorney fees against either party, upon consideration of their financial circumstances, where *594 "the action is for alimony, divorce and alimony, or contempt of court arising out of either an alimony case or a divorce and alimony case[.]" See also Viskup v. Viskup , 291 Ga. 103 , 107 (3), 727 S.E.2d 97 (2012).

2019OCGA § 19-6-2 (a) authorizes attorney fees against either party, upon consideration of their financial circumstances, where *594 "the action is for alimony, divorce and alimony, or contempt of court arising out of either an alimony case or a divorce and alimony case[.]" See also Viskup v. Viskup , 291 Ga. 103 , 107 (3), 727 S.E.2d 97 (2012).

12
Cothran v. Mehoskygreen
gactapp · 2007 · cited in 2 Georgia opinions naming this issue, 2017–2019
2 sentences

2019Cothran , 286 Ga. App. at 641 , 649 S.E.2d 838 .

2019Cothran , 286 Ga. App. at 641 , 649 S.E.2d 838 .

12
Weaver v. Weavergreen
ga · 1993 · cited in 2 Georgia opinions naming this issue, 2004–2016
2 sentences

2016Compare Weaver v. Weaver, 263 Ga. 56 ( 428 SE2d 79 ) (1993) (reversing fee award under OCGA § 19-6-2 where decision to award fees to one party was based on other party’s refusal to settle dispute).

2016Compare Weaver v. Weaver, 263 Ga. 56 ( 428 SE2d 79 ) (1993) (reversing fee award under OCGA § 19-6-2 where decision to award fees to one party was based on other party’s refusal to settle dispute).

12
Jesse Micah Roth v. Allison Bree Craftongreen
gactapp · 2022 · cited in 1 Georgia opinions naming this issue, 2026–2026
2 sentences

2026Accord Roth v. Crafton, 363 Ga. App. 254 , 258(3)(b) ( 870 SE2d 804 ) (2022) (“An award under OCGA § 19-6-2 depends on 18 the financial circumstances of the parties, not their wrongdoing.” (citation modified)).

2026Accord Roth v. Crafton, 363 Ga. App. 254 , 258(3)(b) ( 870 SE2d 804 ) (2022) (“An award under OCGA § 19-6-2 depends on 18 the financial circumstances of the parties, not their wrongdoing.” (citation modified)).

11
Miller v. Millergreen
ga · 2010 · cited in 1 Georgia opinions naming this issue, 2026–2026
2 sentences

2026Compare Miller v. Miller, 288 Ga. 274, 281 (3) ( 705 SE2d 839 ) (2010) (affirming an OCGA § 19-6-2(a)(1) fee award, noting that the trial court had weighed the parties’ financial circumstances, “the awards in the [divorce] decree, interim fee awards, the extent of Wife’s need, and other equitable factors”).

2026Compare Miller v. Miller, 288 Ga. 274, 281 (3) ( 705 SE2d 839 ) (2010) (affirming an OCGA § 19-6-2(a)(1) fee award, noting that the trial court had weighed the parties’ financial circumstances, “the awards in the [divorce] decree, interim fee awards, the extent of Wife’s need, and other equitable factors”).

11
LANDRY v. WALSH; And Vice Versagreen
gactapp · 2017 · cited in 1 Georgia opinions naming this issue, 2022–2022
11
Odum v. Russellgreen
gactapp · 2017 · cited in 1 Georgia opinions naming this issue, 2022–2022
11
Jamie Daniel v. Travis Danielgreen
gactapp · 2021 · cited in 1 Georgia opinions naming this issue, 2021–2021
11
Brewer v. Paulkgreen
gactapp · 2009 · cited in 1 Georgia opinions naming this issue, 2021–2021
11
Trotman v. VELOCITEACH PROJECT MANAGEMENT, LLCgreen
gactapp · 2011 · cited in 1 Georgia opinions naming this issue, 2021–2021
11
Dodson v. Walravengreen
gactapp · 2012 · cited in 1 Georgia opinions naming this issue, 2021–2021
11
Wier v. Wiergreen
ga · 2010 · cited in 1 Georgia opinions naming this issue, 2020–2020
11
Klardie v. Klardiegreen
ga · 2010 · cited in 1 Georgia opinions naming this issue, 2020–2020
11
Taylor v. Taylorgreen
ga · 2008 · cited in 1 Georgia opinions naming this issue, 2020–2020
11
Walton v. Waltongreen
ga · 2009 · cited in 1 Georgia opinions naming this issue, 2019–2019
11
McClain v. McClaingreen
ga · 1976 · cited in 1 Georgia opinions naming this issue, 2019–2019
11
Sutherlin v. Sutherlingreen
ga · 2017 · cited in 1 Georgia opinions naming this issue, 2019–2019
11
McDonogh v. O'CONNORgreen
ga · 1991 · cited in 1 Georgia opinions naming this issue, 2019–2019
11
Hargett v. Dickeygreen
gactapp · 2010 · cited in 1 Georgia opinions naming this issue, 2017–2017
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Georgia. Read the followed side critically anyway.

Also cited on this issue (14)

CaseCitedYears
TIMOTHY GLENN ROSE v. BETHANY DAWN CLARK, F/K/A BETHANY DAWN ROSE green
gactapp · 2021
2 sentences

2025Moreover, though the superior court’s order did not explicit reject Morozova’s 1 Johnson did not file a notice of appeal from the contempt order. request for OCGA § 19-6-2 attorney fees, that section authorizes fees in divorce and alimony cases “to level the financial playing field so that both parties can afford effective representation based on their relative financial circumstances,” Rose v. Clark, 360 Ga. App. 440 , 444 (3) ( 859 SE2d 137 ) (2021), and “is inapplicable to child custody modification actions.” See Wilson v. Perkins, 344 Ga. App. 869 , 873, n. 13 (2) ( 811 SE2d 518 ) (2018).

2025Moreover, though the superior court’s order did not explicit reject Morozova’s 1 Johnson did not file a notice of appeal from the contempt order. request for OCGA § 19-6-2 attorney fees, that section authorizes fees in divorce and alimony cases “to level the financial playing field so that both parties can afford effective representation based on their relative financial circumstances,” Rose v. Clark, 360 Ga. App. 440 , 444 (3) ( 859 SE2d 137 ) (2021), and “is inapplicable to child custody modification actions.” See Wilson v. Perkins, 344 Ga. App. 869 , 873, n. 13 (2) ( 811 SE2d 518 ) (2018).

22024–2025
O'Keefe v. O'Keefe green
ga · 2009
2 sentences

2017As explained in O’Keefe v. O’Keefe, 285 Ga. 805 ( 684 SE2d 266 ) (2009), [t]he purpose of an award of attorney fees pursuant to § 19-6-2 is to ensure effective representation of both spouses so that all issues can be fully and fairly resolved.

2017As explained in O’Keefe v. O’Keefe, 285 Ga. 805 ( 684 SE2d 266 ) (2009), [t]he purpose of an award of attorney fees pursuant to § 19-6-2 is to ensure effective representation of both spouses so that all issues can be fully and fairly resolved.

22017–2017
Vogtle v. Coleman green
ga · 1989
2 sentences

2009The damages authorized by § 9-15-14 “are intended not merely to punish or deter litigation abuses but also to recompense litigants who are forced to expend their resources in contending with [abusive litigation].” Ferguson v. City of Doraville, 186 Ga. App. 430, 440 ( 367 SE2d 551 ) (1988), overruled on other grounds, Vogtle v. Coleman, 259 Ga. 115 ( 376 SE2d 861 ) (1989).

2009The damages authorized by § 9-15-14 “are intended not merely to punish or deter litigation abuses but also to recompense litigants who are forced to expend their resources in contending with [abusive litigation].” Ferguson v. City of Doraville, 186 Ga. App. 430, 440 ( 367 SE2d 551 ) (1988), overruled on other grounds, Vogtle v. Coleman, 259 Ga. 115 ( 376 SE2d 861 ) (1989).

22003–2009
Wilson v. Perkins. green
gactapp · 2018
12025–2025
HAIR RESTORATION SPECIALISTS, INC. D/B/A HAIR RESTORATION SPECIALISTS OF ATLANTA v. STATE OF GEORGIA green
gactapp · 2021
2 sentences

2025“Compliance with the discretionary appeals procedure is jurisdictional.” Hair Restoration Specialists v. State of Ga., 360 Ga. App. 901 , 903 ( 862 SE2d 564 ) (2021) (citation and punctuation omitted).

2025“Compliance with the discretionary appeals procedure is jurisdictional.” Hair Restoration Specialists v. State of Ga., 360 Ga. App. 901 , 903 ( 862 SE2d 564 ) (2021) (citation and punctuation omitted).

12025–2025
Waits v. Waits green
gactapp · 2006
12019–2019
Leggette v. Leggette green
ga · 2008
12018–2018
Brady v. Brady green
ga · 1972
12016–2016
Floyd v. Floyd green
ga · 2012
12016–2016
Nesbit v. Nesbit green
gactapp · 2009
12014–2014
Moore v. Moore green
gactapp · 2011
12014–2014
Walls v. Walls green
ga · 2012
12014–2014
Eldridge v. Eldridge green
ga · 2012
12014–2014
Cotting v. Cotting green
gactapp · 2003
12004–2004

Statutes the citing opinions construe

GA § 19-6-2 (55) GA § 9-15-14 (37) GA § 19-9-3 (12) GA § 19-6-15 (11) GA § 13-6-11 (7) GA § 5-6-34 (7) GA § 5-6-35 (5) GA § 19-6-1 (4) GA § 19-9-6 (3) GA § 5-6-13 (3) GA § 9-11-13 (3) GA § 9-11-60 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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