Gresham-Green v. Mainones, 290 Ga. 721

Gresham-Green and Mainones married in 2006 and divorced by Final Decree on May 13, 2011.
Trial court awarded primary custody to Husband and Wife was ordered to pay child support.
Wife appealed to the Georgia Supreme Court under Rule 34(4).
Guardian ad litem testified at the final hearing; the GAL report itself was not admitted into evidence.
Trial court’s order did not reference the GAL report and no record shows reliance on it; error claimed for non-admission deemed harmless.
Temporary order deviated from presumptive child support, allocating 80% of costs to Husband due to Wife’s custody; mortgage at issue; final order used worksheets for income; incomes accepted as true.

Issue	Plaintiff's Argument	Defendant's Argument	Held
GAL report admissibility affecting custody	Gresham-Green argues trial court erred by relying on a non-admitted GAL report.	Mainones contends GAL testified and no reliance on the report occurred.	Harmless error; GAL testified and order did not rely on the report.
Temporary support and income consideration	Wife contends no temporary support and income not considered in final order.	Husband argues deviation authorized and incomes were properly used.	No error; deviation permitted; incomes accepted from worksheets.
Finding custody and delegation of findings	Wife claims improper delegation to Husband via drafted Final Decree; insufficient findings.	Husband argues drafting by counsel is permissible; forfeiture for not requesting more findings.	Permissible procedure; no failure to make required findings; judgment affirmed.

Finklea v. Finklea, 290 Ga. 357 (2012) (forfeiture when no request for additional findings made)
Gallo v. Kofler, 289 Ga. 355 (2011) (drafting of orders allowed; findings context)