Fladger v. Fladger, 296 Ga. 145

Father and Mother married in 1994; two children were aged ten and six when Mother filed for divorce in 2011.
Divorce order issued December 13, 2012, amended December 5, 2013; issue of child support was argued on high-income deviation grounds.
Mother earned about $5,097 monthly as a teacher; Father had a 2011 income of about $639,573.38 and approximately $674,000 in 2010.
Initial child support set at $5,052 per month starting January 1, 2013; 91.4% of total combined income attributed to Father on the worksheet.
A $2,000 upward deviation was applied due to Father’s high income; the written factual findings for deviation were left blank.
In December 2013, the court amended to affirm high-income deviation but failed to provide the third required finding tying deviation to the best interests and unjust application of guidelines; this led to a reversible error and remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the deviation requires written findings under OCGA 19-6-15(c)(2)(E)	Fladger argues deviation lacks required findings after presumption	Mother contends findings exist in the amendment tying to high income and disparity	Yes; reversal and remand for full written findings

Holloway v. Holloway, 288 Ga. 147 (Ga. 2010) (written findings mandatory for deviation; reverse if missing)
Stowell v. Huguenard, 288 Ga. 628 (Ga. 2011) (mandatory findings for deviations; remand when incomplete)
Turner v. Turner, 285 Ga. 866 (Ga. 2009) (requires proper findings to support deviations)
Brogdon v. Brogdon, 290 Ga. 618 (Ga. 2012) (emphasizes statutory prerequisites for deviations)
Black v. Black, 292 Ga. 691 (Ga. 2013) (remand for lack of findings; deviation review standards)
Spurlock v. Dept. of Human Resources, 286 Ga. 512 (Ga. 2010) (transcript absence does not excuse missing statutory findings)