Naylor v. Oden

The paternal uncle and his wife, by prior orders of the Circuit Court of DeKalb County, were awarded custody of their niece, now age seven. The mother of the child was given visitation privileges of three hours every other month at the home of the uncle and aunt.

Approximately three years after the last of the aforementioned orders the paternal uncle and aunt sought, by modification, to terminate the mother's visitation. The mother counter-petitioned, requesting that she be awarded custody or that visitation be extended.

After an ore tenus hearing, the learned trial judge terminated the…