Patterson v. Hragyil, 322 Ga. App. 329

Patterson appeals a trial court award of attorney fees to Hragyil under OCGA § 9-15-14 (b).
Patterson argues the court relied on information outside the record, did not specify conduct supporting fees, and did not limit fees to sanctionable conduct.
She also challenges the denial of her cross-motion for attorney fees under OCGA § 9-15-14 (b).
Timeline: August 31, 2011 Patterson sought back child support; September 22, 2011 complaint filed; October 26, 2011 mediation; December 9, 2011 DNA results show not the father; December 12, 2011 dismissal; January 12, 2012 motion by Hragyil for fees; Patterson cross-moves.
The trial court awarded fees to Hragyil, stating Patterson’s conduct was substantially frivolous and unnecessarily expanded the proceedings.
The appellate court reversed the fee award to Patterson and affirmed the denial of her cross-motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the fee award under 9-15-14 (b) erroneous?	Patterson: court relied on outside-record info, failed to tie fees to sanctionable conduct, and did not cap fees to sanctionable conduct.	Hragyil: court acted within discretion applying 9-15-14 (b) for frivolous or expanded proceedings.	Yes; reversed the fee award.
Was Patterson's cross-motion for fees properly denied?	Patterson contends she incurred fees defending the fee motion and should be compensated.	Hragyil argues no abuse of discretion in denying cross-motion.	No abuse; cross-motion denied; affirmed.

Dodson v. Walraven, 318 Ga. App. 586 (Ga. App. 2012) (fees denied when conduct not substantially frivolous)
MARTA v. Doe, 292 Ga. App. 532 (Ga. App. 2008) (no abuse in denying fees under 9-15-14 (b))
Kilgore v. Sheetz, 268 Ga. App. 761 (Ga. App. 2004) (no abuse in denying fees under 9-15-14 (b))
Abt v. Abt, 289 Ga. 166 (Ga. 2011) (abuse-of-discretion standard for 9-15-14 (b) awards)
Nelson & Hill, P.A. v. Wood, 245 Ga. App. 60 (Ga. App. 2000) (pleadings/motions judged by substance, not nomenclature)