Coppedge v. Coppedge, 298 Ga. 494

Final divorce decree (Dec 2006) incorporated the settlement; husband must pay $2,000 monthly child support and share private school and after-school/summer care expenses at St. Luke.
Decree provides that increases or decreases in St. Luke expenses are divided 50/50 and husband’s direct cash amount is adjusted; if children switch to a more expensive private school, husband’s obligation is limited to St. Luke amounts.
In spring 2010, wife removed the children from St. Luke and hired a babysitter for summer/after-school care at home.
In May 2010, husband petitioned to modify custody/visitation and reduced his child-support payment by the amount of his share of St. Luke after-school/summer care.
Wife counterclaimed for contempt for about $7,000 underpayment, based on what husband would have paid if the children remained in St. Luke programs.
Trial court denied modification, held husband in contempt for failing to pay the babysitter share and for one missed visitation; concluded decree did not confine to St. Luke and no court order required to adjust support.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Contempt for babysitter expenses	Coppedge argues decree only obligates share of St. Luke care, not in-home babysitter.	Coppedge contends adjustment provision ambiguous; could allow deduction for non-St. Luke care only if interpreted broadly.	Ambiguity; contempt reversed.
Due process - denial of custodial time on birthday	Husband’s conduct violated court-ordered custodial time; contempt justified.	No abuse of discretion; evidence supports denial of custodial time.	Contempt upheld for denial of custodial time.
Modification of visitation	Court should modify visitation based on best interests with new evidence.	No clear abuse; children thriving under current schedule; discretion favored upholding ruling.	No clear abuse; denial affirmed.
Due process and timing of final order	Eight-month delay deprived husband of due process.	Delay reasonable given post-trial motions; due process satisfied with notice and opportunity to be heard.	Delay not a due process violation.

Hall v. Day, 273 Ga. 838 (2001) (contract terms from settlement decree interpreted for intent; plain meaning enforced)
Morgan v. Morgan, 288 Ga. 417 (2011) (contempt requires clear, definite terms informing duties)
Farris v. Farris, 285 Ga. 331 (2009) (due process in contempt requires express duties in order)
Shore v. Shore, 253 Ga. 183 (1984) (due process and consideration of all facts up to judgment)
Urquhart v. Urquhart, 272 Ga. 548 (2000) (trust in trial court’s resolution of custody evidence conflicts)
Cobb County Sch. Dist. v. Barker, 271 Ga. 35 (1999) (due process and notice standards in judicial proceedings)
Arnold v. Arnold, 236 Ga. 594 (1976) (contempt requires definite terms in decree; not automatic)
Roca Properties, LLC v. Dance Hotlanta, Inc., 327 Ga. App. 700 (2014) (ambiguous contract terms may invite parol evidence)