Brogdon v. Brogdon, 290 Ga. 618

Ten-year marriage between Joshua E. Brogdon and Tawnya S. Brogdon produced a child.
Divorce filed July 9, 2009; final judgment entered August 3, 2010 with attached Child Support Worksheet and Schedule E.
Divorce decree awarded Wife primary physical custody; Husband income found at $12,000/month, Wife income imputed at $1,257/month.
Final order calculated child support of $1,816/month to Wife; equitable division included $96,250 to Wife payable in $2,000/month installments.
Husband appealed; Supreme Court granted discretionary review; Court reversed in part and remanded for proper written findings regarding extraordinary educational expenses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Written findings for extraordinary educational expenses	Brogdon	Brogdon	Remand required; lack of written findings invalidates deviation
Pro forma use of basic child support obligation terminology	Brogdon	Brogdon	No reversible error; mislabeling did not affect calculations
Extracurricular expenses deviation as a mandatory finding	Brogdon	Brogdon	No mandatory deviation supported; stipulation alone insufficient without findings
Security agreement to secure equitable division payments	Brogdon	Brogdon	No abuse of discretion; such structure is permissible to assure payment
Attorney fees awarded under OCGA § 19-6-2(a)	Brogdon	Brogdon	Presumed properly considered; no error shown

Holloway v. Holloway, 288 Ga. 147 (Ga. 2010) (written findings mandatory when deviations are applied)
Spurlock v. Dept. of Human Resources, 286 Ga. 512 (Ga. 2010) (required findings for deviation review; lack triggers reversal)
Turner v. Turner, 285 Ga. 866 (Ga. 2009) (must have findings to support deviations; improper deviation review)
Rumley-Miawama v. Miawama, 284 Ga. 811 (Ga. 2009) (findings needed when applying specified deviations)
Spurlock v. Dept. of Human Resources, 286 Ga. 512 (Ga. 2010) (standard for reviewing final child support orders with missing findings)