Johnson v. Johnson, 290 Ga. 359

Divorce judgment and decree between Father Roy Johnson and Mother Ping Hu Johnson in December 2010.
Judgment incorporated a parenting plan giving Mother primary physical custody and supervised overnight visitation for Father.
Plan allowed a therapist treating the child to approve a reasonable adult for supervision and to determine phasing out of supervision.
Father moved for a new trial alleging the supervision-termination provision is an improper self-executing modification contingent on a non-judge determination.
Trial court denied the motion; appellate discretionary review granted under the Pilot Project; court ultimately reversed the self-executing provision and remanded to strike it.
Decision decided January 9, 2012; Pilot Project expired; Supreme Court Rule 34 replaced the Pilot Project in 2011.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the supervision-termination provision is an improper self-executing modification.	Johnson argues the provision automatically changes visitation without judicial review.	Johnson contends the provision serves the child's best interests and is permissible.	Invalid self-executing change; must be stricken and requires court review.

Scott v. Scott, 276 Ga. 372 (Ga. 2003) (self-executing visitation changes allowed if not conflicting with best interests)
Wrightson v. Wrightson, 266 Ga. 493 (Ga. 1996) (trial court must decide modification, not delegate to expert)
Dellinger v. Dellinger, 278 Ga. 732 (Ga. 2004) (material change generally violates best-interests standard)
Sigal v. Sigal, 289 Ga. 814 (Ga. 2011) (supervised visitation provisions are for child's welfare)