Consent to consideration of grounds for revocation.

- Guardian of the property testified that the guardian was in court to explain to the court what the documentation in the court file showed had occurred, to explain further with some facts that were not in the file, and to respond to the answer of the guardian ad litem; the guardian testified about the grounds for the guardian's revocation, later considered by the court in its revocation order, and it followed that the guardian expressly or by implication consented to the consideration of those grounds in the order revoking the guardian's letters. In re Longino, 281 Ga. App. 599, 636 S.E.2d 683 (2006), cert. denied, 2007 Ga. LEXIS 92 (Ga. 2007).

Revocation proper.

- Revocation of a guardian of the property's letters of guardianship under former O.C.G.A. §§ 29-2-45(a) and29-5-9(a)(1), now codified at O.C.G.A. § 29-5-92, was proper as the guardian was issued a citation notifying the guardian that the guardian might not be acting in the ward's best interest, the citation gave the guardian sufficient notice to enable the guardian to answer the charges, and the guardian testified that the guardian was going to respond to a guardian ad litem's report; there was evidence that: (1) the 90-year-old ward had over $2,000,000 in assets, but was not getting the care the ward needed as the assets were frozen in litigation over the guardian's efforts to void or move a trust; (2) there was evidence that the guardian used or intended to use the guardian's position to place the guardian as the sole trustee; and (3) the guardian had informed the probate court that the guardian did not consider the guardian's brother to be trustworthy, yet the guardian proposed that the brother be appointed as the guardian of the property. In re Longino, 281 Ga. App. 599, 636 S.E.2d 683 (2006), cert. denied, 2007 Ga. LEXIS 92 (Ga. 2007).

Liability for punitive damages.

- Conservator's bond pursuant to O.C.G.A. § 29-5-40 et seq. does not cover punitive damages. In re Estate of Gladstone, 303 Ga. 547, 814 S.E.2d 1 (2018).

Judgment that a conservator's bond covered punitive damages even though such damages were not expressly provided for under O.C.G.A. § 29-5-40 et seq. or under the provisions of the bond itself was reversed because a conservator's bond pursuant to § 29-5-40 et seq. does not cover punitive damages. In re Estate of Gladstone, 303 Ga. 547, 814 S.E.2d 1 (2018).

Punitive damages upheld.

- Probate court did not err in awarding punitive damages, as the conservator and the surety were on notice that the conservator's actions would be examined in connection with O.C.G.A. § 29-5-92, and the record supported the conclusion that punitive damages were appropriate. In re Estate of Gladstone, 341 Ga. App. 72, 798 S.E.2d 660 (2017).