Order transferring custody of minor child from paternal grandmother to child’s mother, REVERSED, trial court ERRED in depriving father and grandmother of opportunity to question guardian ad litem about results of his investigation, since father and grandmother bore burden of proving that return of custody to mother would harm child and that remaining with grandmother was in child’s best interest; trial court ERRED in failing to include written findings in its child support award; trial court acted within its discretion in prohibiting any party from having unrelated overnight guests of opposite sex during periods of physical custody or visitation.

Simmons v. Williams, A07A2218 (03/27/08), 08 FCDR 1256

From:  Fulton County Daily Report (04/18/08)