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Eleazer v. Eleazer

trial court erred in awarding child support without making written findings as required by O.C.G.A. § 19-6-15.

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We granted appellant Reginald Eleazer’s application for a discretionary appeal in this divorce action to determine whether the trial court’s failure to make the written findings required by OCGA § 19-6-15 a for child support awards was reversible error. Because written findings are required under OCGA § 19-6-15 a, we vacate the trial court’s child support award and remand the case to the trial court.

Reginald and Sonya Eleazer were divorced in August 2001 after a bench trial. The final judgment awarded Sonya legal and physical custody of the parties’ two minor children and directed Reginald to pay child support in the amount of $2,500.00 per month for each of their two children. The final judgment did not include written findings as to the parties’ gross incomes, calculations as to the application of the statutory child support guidelines, or written findings as to the special circumstances justifying departure from the guidelines’ applicable range. Reginald contends that the trial court erred by failing to enter written findings of the parties’ gross incomes and the presence or absence of special circumstances concerning the child support award in accordance with OCGA § 19-6-15 a.

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