section 19-6-15(c) written findings of fact (Georgia) · Go Syfert
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section 19-6-15(c) written findings of fact in Georgia

9 Georgia opinions name it 2 courts 2010–2022 1 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 (9)

CaseFollowedCited
Fladger v. Fladgergreen
ga · 2014 · cited in 2 Georgia opinions naming this issue, 2015–2022
2 sentences

2022Fladger v. Fladger, 296 Ga. 145, 149 (2) ( 765 SE2d 354 ) (2014); Brogdon v. Brogdon, 290 Ga. 618, 623 (5) (b) ( 723 SE2d 421 ) (2012) (noting that it is well-settled that the written findings required under OCGA § 19-6-15 (i) (1) (B) are “mandatory”) (citations omitted).

2022Fladger v. Fladger, 296 Ga. 145, 149 (2) ( 765 SE2d 354 ) (2014); Brogdon v. Brogdon, 290 Ga. 618, 623 (5) (b) ( 723 SE2d 421 ) (2012) (noting that it is well-settled that the written findings required under OCGA § 19-6-15 (i) (1) (B) are “mandatory”) (citations omitted).

22
Haesun Park-Poaps v. Richard C. Poapsgreen
gactapp · 2019 · cited in 2 Georgia opinions naming this issue, 2020–2020
2 sentences

2020But written factual findings are necessary only “[i]f the trial court determines that a deviation from the presumptive child support amount is warranted[.]” Park-Poaps, 351 Ga. App. at 866 (6).

2020But written factual findings are necessary only “[i]f the trial court determines that a deviation from the presumptive child support amount is warranted[.]” Park-Poaps, 351 Ga. App. at 866 (6).

22
Brogdon v. Brogdongreen
ga · 2012 · cited in 1 Georgia opinions naming this issue, 2022–2022
2 sentences

2022Fladger v. Fladger, 296 Ga. 145, 149 (2) ( 765 SE2d 354 ) (2014); Brogdon v. Brogdon, 290 Ga. 618, 623 (5) (b) ( 723 SE2d 421 ) (2012) (noting that it is well-settled that the written findings required under OCGA § 19-6-15 (i) (1) (B) are “mandatory”) (citations omitted).

2022Fladger v. Fladger, 296 Ga. 145, 149 (2) ( 765 SE2d 354 ) (2014); Brogdon v. Brogdon, 290 Ga. 618, 623 (5) (b) ( 723 SE2d 421 ) (2012) (noting that it is well-settled that the written findings required under OCGA § 19-6-15 (i) (1) (B) are “mandatory”) (citations omitted).

11
Kennedy v. Kennedygreen
gactapp · 2011 · cited in 1 Georgia opinions naming this issue, 2020–2020
2 sentences

2020See Kennedy v. Kennedy, 309 Ga. App. 590, 592-93 (1) (a) & (b) ( 711 SE2d 103 ) (2011) (concerning the need for written findings when a deviation is ordered). 3.

2020See Kennedy v. Kennedy, 309 Ga. App. 590, 592-93 (1) (a) & (b) ( 711 SE2d 103 ) (2011) (concerning the need for written findings when a deviation is ordered). 3.

11
Wallace v. Wallacegreen
ga · 2014 · cited in 1 Georgia opinions naming this issue, 2015–2015
2 sentences

2015OCGA § 19-6-15 (c) (2) (E); see Fladger v. Fladger, 296 Ga. 145, 147 (2) ( 765 SE2d 354 ) (2014) (explaining that if a trial court determines that a deviation from the presumptive child-support amount is applicable, the court must include written findings of fact under OCGA § 19-6-15 (c) (2) (E)); Wallace v. Wallace, 296 Ga. 307, 308 (1) ( 766 SE2d 452 ) (2014) (same).

2015OCGA § 19-6-15 (c) (2) (E); see Fladger v. Fladger, 296 Ga. 145, 147 (2) ( 765 SE2d 354 ) (2014) (explaining that if a trial court determines that a deviation from the presumptive child-support amount is applicable, the court must include written findings of fact under OCGA § 19-6-15 (c) (2) (E)); Wallace v. Wallace, 296 Ga. 307, 308 (1) ( 766 SE2d 452 ) (2014) (same).

11
Strunk v. Strunkgreen
ga · 2013 · cited in 1 Georgia opinions naming this issue, 2014–2014
1 sentence

2014While the trial court can certainly deviate from the presumptive amount of child support in a modification action, if it does so, it must “enter a written order specifying the basis for the modification . . . and shall include all of the information set forth in paragraph (2) of subsection (c) of this Code section.” OCGA § 19-6-15 (k) (4). 11 And, as this Court has previously noted, OCGA § 19-6-15 (c) (2) (E) requires written findings of fact that a deviation applies and the reasons for the deviation, the amount of child support that would have been required if the deviation were not granted,

11
Turner v. Turnergreen
ga · 2009 · cited in 1 Georgia opinions naming this issue, 2013–2013
1 sentence

2013Turner, 285 Ga. at 868 (2).

11
Carson v. Carsongreen
gactapp · 1997 · cited in 1 Georgia opinions naming this issue, 2010–2010
2 sentences

2010To the extent that Carson v. Carson, 226 Ga. App. 659, 660 (3) ( 487 SE2d 447 ) (1997) holds otherwise, it is hereby overruled.

2010To the extent that Carson v. Carson, 226 Ga. App. 659, 660 (3) ( 487 SE2d 447 ) (1997) holds otherwise, it is hereby overruled.

11
Department of Human Resources v. Wilcoxgreen
gactapp · 1996 · cited in 1 Georgia opinions naming this issue, 2010–2010
2 sentences

2010See also Dept. of Human Resources v. Wilcox, 219 Ga. App. 757, 758 ( 466 SE2d 662 ) (1996) (where no transcript and no written findings pursuant to OCGA § 19-6-15, order modifying child support pursuant to DHR review vacated and case remanded for written findings).

2010See also Dept. of Human Resources v. Wilcox, 219 Ga. App. 757, 758 ( 466 SE2d 662 ) (1996) (where no transcript and no written findings pursuant to OCGA § 19-6-15, order modifying child support pursuant to DHR review vacated and case remanded for written findings).

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 (1)

CaseCitedYears
McCarthy v. Ashment-Mccarthy green
ga · 2014
2 sentences

2019In McCarthy v. Ashment- McCarthy, 295 Ga. 231 ( 758 SE2d 306 ) (2014), our Supreme Court considered whether the trial court’s failure to comply with the requirement to make written findings under OCGA § 19-6-15 can be waived by failing to first raise the issue of compliance in the trial court.

2019In McCarthy v. Ashment- McCarthy, 295 Ga. 231 ( 758 SE2d 306 ) (2014), our Supreme Court considered whether the trial court’s failure to comply with the requirement to make written findings under OCGA § 19-6-15 can be waived by failing to first raise the issue of compliance in the trial court.

12019–2019

Statutes the citing opinions construe

GA § 19-6-15 (9) GA § 19-6-2 (5) GA § 9-15-14 (5) GA § 19-9-3 (4) GA § 13-6-11 (3) GA § 5-6-34 (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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