Finklea v. Finklea, 290 Ga. 357

Trial court entered final divorce judgment on April 4, 2011; Wife appeals discretionary ruling and Court affirms.
Custody order awarded primary physical custody to Husband; Wife alleges trial court failed to consider evidence of family violence under OCGA § 19-9-3(a)(3)(P) and § 19-9-3(a)(4)(A)-(D).
No party requested written findings of fact supporting the custody award; statute allows written findings only if requested; court cites Gallo v. Kofler on non-mandatory written findings absent request.
Record shows both spouses testified extensively about acts of family violence; multiple police reports filed; the trial court stated judgment after hearing all evidence.
Standard of review is abuse of discretion; court defers to trial court’s custody decision if supported by some evidence; custody affirmed with Wife having joint legal custody and extensive visitation.
Child support calculation used Husband’s gross income of $2,200; Wife sought inclusion of $600 monthly rental income but had asked the court to use the worksheet; doctrine of induced error bars complaint per Simmons v. Simmons.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the court err by not considering family-violence evidence	Finklea contends the court ignored evidence of family violence under OCGA 19-9-3(a)(3)(P) and (a)(4).	Husband argues discretion allowed; no mandatory written findings unless requested.	No abuse; court considered evidence; no written findings required absent request.
Whether custody award constitutes an abuse of discretion	Wife asserts the court erred in granting primary custody to Husband given violence history.	Husband contends the court acted within broad discretion and chose a fit parent.	No abuse; decision supported by evidence and deferential standard.
Whether the trial court erred in child-support calculation	Wife argues to add $600 rental income to Husband’s gross income.	Wife asked to use her worksheet showing $2,200; Simmons bars complaint about wage amount used.	No error; Wife barred from challenging amount she requested to be used.

Haskell v. Haskell, 286 Ga. 112 (2009) (abuse of discretion standard in custody matters)
Gallo v. Kofler, 289 Ga. 355 (2011) (written findings not mandatory absent request in custody cases)
Simmons v. Simmons, 288 Ga. 670 (2011) (induced-error doctrine bars complaints about requested wage amounts)