Spurlock v. Department of Human Resources

Scott Spurlock Father and Lois Spurlock Mother were divorced in 2005. Pursuant to the final divorce decree, Father was ordered to pay monthly child support of $1,063. Three years later, he initiated a review of that child support order by the Department of Human Resources DHR pursuant to OCGA § 19-11-12. DHR recommended that his child support obligation be reduced to $718 per month, and petitioned the trial court to adopt that recommendation. The trial court did not fully adopt DHR’s recommendation, but did order that Father’s child support obligation be reduced to $1,000 per month. Acting pro se, Father appealed to the Court of Appeals pursuant to its grant of an application for discretionary appeal. The Court of Appeals then transferred the case to this Court based upon our jurisdiction over divorce and alimony cases. Ga. Const. Of 1983, Art. VI, Sec. VI, Par. III 6.

1. We initially determine whether a modification of child support arising out of a DHR review under OCGA § 19-11-12 invokes this Court’s divorce and alimony jurisdiction.