Supreme Court of Georgia

Ehlers v. Ehlers

November 28, 1994264 Ga. 668

Summary

The court held that written findings are required when a child-support award departs from the statutory guidelines, and remanded for those findings. It also held that indirect payments may be considered only when varying the final award, and that the initial guideline calculation must be based on the children for whom support is being determined, not all children the obligor supports. Justice Hunstein concurred while advocating written findings in every guideline case, and Chief Justice Hunt, joined by Justice Sears, would have affirmed rather than remanded.