Abt v. Abt, 289 Ga. 166

After 16 years of marriage, Michael Abt filed for divorce from Kerry Abt; two children were involved.
Initial trial court order granted joint legal custody with Kerry as primary physical custodian; Kerry allowed her boyfriend to move into the marital home.
Husband amended the complaint to add adultery; custody elections by the children vacillated in response to the boyfriend and his residence; a guardian ad litem was appointed.
Before trial the parties settled disputed custody issues; remaining issues were tried to a jury; a verdict was entered and challenged via a motion for new trial.
The parties entered a consent agreement adopted by the court: a new trial was granted, a non-jury trial was held, and restrictions prohibited the children from being in the presence of Kerry's boyfriend.
Following the non-jury trial, the court entered a final divorce judgment and awarded husband attorney fees under OCGA § 9-15-14(b); Kerry sought discretionary appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the attorney fee award under OCGA § 9-15-14(b) was proper.	Abt argues Kerry's conduct expanded litigation, justifying fees.	Kerry contends fees were improper expansion beyond § 9-15-14(b) scope.	Yes; the award was proper and not an improper expansion.

O'Keefe v. O'Keefe, 285 Ga. 805 (Ga. 2009) (fees for abusive litigation purpose)
Haggard v. Bd. of Regents, etc., 257 Ga. 524 (Ga. 1987) (abuse of discretion standard for fees)
Taylor v. Taylor, 282 Ga. 113 (Ga. 2007) (trial court can award fees for unnecessarily expanding litigation)
Wright v. Wright, 277 Ga. 133 (Ga. 2003) (Family Law Pilot Project context for appealability)