Ehlers v. Ehlers

Thompson, Justice.

We granted a discretionary appeal in this child support modification case to determine three questions: 1) Must a trier of fact, upon modifying an award of child support, enter written findings of special circumstances in order to deviate, up or down, from the child support guidelines of OCGA § 19-6-15 (b)? 2) In determining the amount of child support to be paid by an obligor, can the trier of fact give credit for payments other than direct cash child support payments (e.g., medical payments)? 3) In calculating the amount of child support one is obligated to pay, should the…