Jackson v. Irvin, 316 Ga. App. 560

Jackson appeals a trial court order establishing legitimation, custody, and child support for her four-year-old child with Irvin.
Dispute focuses on whether the presumptive child support should be deviated because Irvin has a subsequent child to support.
Presumptive monthly support was calculated at $2,756.94; the court reduced it by $907 to $1,850 via a nonspecific deviation.
Evidence showed little more than Irvin’s subsequent child existence; no clear information about the other child’s living situation or support obligations.
The court noted Irvin’s potential future earnings and agent commissions, but the record did not prove a valid basis for the deviation.
This Court reverses in part, remands for proceedings consistent with the opinion, and otherwise affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Deviation based on other child	Jackson	Irvin	Deviation improper; not supported by evidence
Reliance on facts not in evidence	Jackson	Irvin	Upheld; some findings unsupported, but material conclusions supported
Use of wrong standard	Jackson	Irvin	No error; appropriate guidelines applied
Health insurance obligation	Jackson	Irvin	Court did not abuse discretion in health insurance ruling
Attorney fees	Jackson	Irvin	Not reviewable; no abuse of discretion found

Stowell v. Hugue-nard, 288 Ga. 628 (2011) (child support guidelines are rebuttable presumption; deviations require findings)
Turner v. Turner, 285 Ga. 866 (2009) (review standards for deviation from presumptive support)
Hamlin v. Ramey, 291 Ga. App. 222 (2008) (abuse of discretion standard for deviation decisions)
Dupree v. Dupree, 287 Ga. 319 (2010) (need harm showing for error in family matters)
Chariot v. Goldwire, 310 Ga. App. 463 (2011) (OCGA § 19-7-50 attorney fees authority)
Galvin v. Galvin, 288 Ga. 125 (2010) (health insurance responsibilities of parents; discretionary discretion)