Demmons v. Wilson-Demmons, 293 Ga. 349

Husband and Wife married December 23, 2002 and have two children together; Husband also pays child support for two minor children from a prior marriage.
During marriage, Husband worked as a firefighter and held a part-time job at Lowe's; Wife was a licensed physician but not board-certified.
Wife filed for divorce in February 2010; final divorce order entered April 21, 2011; trial court reserved attorney fees but later denied Wife’s fee motion on February 7, 2012.
This Court granted Husband’s Supreme Court Rule 34 (4) application to appeal a final judgment determined to have possible merit.
Court vacated the Final Order and remanded to require explicit findings of each party’s gross monthly income and proper incorporation of the income findings into the Final Order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Final Order failed to include written gross income findings	Husband contends the Final Order lacked explicit gross income findings as required.	Wife did not dispute the lack of findings; the defect affected child support calculations.	Remand required to include gross income findings.
Effect of missing findings on child support and related issues	Actual income findings are necessary to reevaluate child support.	Without findings, other enumerations cannot be adequately addressed.	Case remanded for proper findings and potential adjustment of child support; other issues held in abeyance.

Holloway v. Holloway, 288 Ga. 147 (Ga. 2010) (necessity of proper findings on final orders)
Kuriatnyk v. Kuriatnyk, 286 Ga. 589 (Ga. 2010) (need for precise income-related findings in final decree)
Southerland v. Southerland, 278 Ga. 188 (Ga. 2004) (remand for proper income findings and reconsideration of support)