Hammonds v. Parks

MCFADDEN, Judge.

This case originated as a contempt action: the custodial father, Lorenzo Hammonds, alleged that the child’s mother, Eden Parks, had violated a provision of the custody order. Contrary to the rule that petitions for change of custody brought against custodial parents must be brought as separate actions, as well as the rule that such petitions must be brought in the custodial parent’s county of residence, OCGA § 19-9-23, the trial court granted the mother’s oral motion for change of custody. She was without jurisdiction to do so, and we reverse. That unauthorized custody ruling…