Judgment of trial court REVERSED in father’s action under OCGA § 19-11-12 for modification of his monthly child support obligation as trial court applied high income deviation from presumptive child support award without making all required findings under OCGA § 19-6-15 (c)(2) – trial court’s order failed to state how application of presumptive amount of child support would be unjust or inappropriate and how upward deviation would serve best interest of children; Court has jurisdiction over appeals from orders in child support modification proceedings, which arise from prior divorce or alimony action, regardless of code section under which parties pursued modification, i.e. OCGA § 19-11-12 or 19-6-19, and Court had jurisdiction in this case, because case involved alimony for support of children; striking and redocketing appeal was not necessary to preserve Court’s ultimate jurisdiction in this case.

Spurlock v. Department of Human Resources, S09A1475 (2/15/2010), 10 FCDR 399.

From:  Fulton County Daily Report, 2/26/2010.