Crutchfield v. Lawson, 294 Ga. 407

Paulding County Superior Court entered a final divorce decree on April 17, 2008.
Wife filed a contempt action in Cobb County Superior Court on September 9, 2011.
Husband answered in Cobb and cross-applied for contempt, challenging Cobb's jurisdiction, on October 18, 2011.
May 3, 2012 hearing: parties consented in open court to Cobb County jurisdiction.
Cobb County court conducted hearings and ultimately found Husband in contempt.
Husband moved to set aside the contempt judgment, arguing lack of subject matter jurisdiction; trial court denied; he appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the case lies in subject matter jurisdiction or venue	Crutchfield argues Cobb lacked subject matter jurisdiction.	Lawson contends Cobb had proper venue under Buckholts and consent to Cobb's jurisdiction.	Venue, not subject matter jurisdiction; consent barred challenge to venue; judgment affirmed.

Goodrum v. Goodrum, 202 Ga. 135 (1947) (contempt power tied to the offended court)
Jacob v. Koslow, 282 Ga. 51 (2007) (distinguishes subject matter jurisdiction from venue)
Buckholts v. Buckholts, 251 Ga. 58 (1983) (divorce/alt-venue rule; counterclaim for contempt in non-original court)
Parris v. Douthit, 287 Ga. 119 (2010) (venue waiver when not properly raised under statute)
Robinson v. Attapulgus Clay Co., 55 Ga. App. 141 (1937) (subject matter/venue treatment in early determinative context)
Hopkins v. Hopkins, 237 Ga. 845 (1976) (distinguishes jurisdiction and venue concepts)
Abushmais v. Erby, 282 Ga. 619 (2007) (equitable considerations in contempt/venue)
Doke v. Doke, 248 Ga. 514 (1981) (contempt mechanics in divorce context)
Herring v. Herring, 246 Ga. 462 (1980) (procedural aspects of contempt and venue)