Rowden v. Rowden, 290 Ga. 65

Divorce finalized May 26, 2010; Wife awarded primary physical custody and child support.
Evidence showed both parents fit but poor ability to communicate and cooperate about the children.
Wife’s income: $200,000 in 2009; dropped to $80,000 due to practice losses; current job $40,000 part-time since Feb 1, 2010.
Husband’s income at trial: $26,000.
Trial court awarded Wife primary custody and set child support; Husband appeals; Georgia Supreme Court affirms.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Custody award to Wife was proper?	Rowden contends custody should be shared or awarded to Husband.	Rowden argues trial court abused its discretion in denying him custody.	No abuse; award to Wife affirmed.
Should willful underemployment be considered for child support?	Rowden argues underemployment should reduce support under OCGA 19-6-15(f)(4)(D).	Rowden contends trial court should adjust support based on Wife’s income reduction.	Court properly considered reasons for Wife’s income change; no modification required.
Abatement of child support during summer visitation?	Rowden seeks abatement during summer visitation.	No duty to abate absent a court order or clear best-interest showing.	No abatement; presumptive support preserved.

LaFont v. Rouviere, 283 Ga. 60, 656 S.E.2d 522 (Georgia Supreme Court 2008) (custody awards defer to trial court discretion when evidence supports ruling)
Atkins v. Zachary, 243 Ga. 453, 254 S.E.2d 837 (Georgia Supreme Court 1979) (no automatic abatement of child support during visitation absent court order)
James v. James, 246 Ga. 233, 271 S.E.2d 151 (Georgia Supreme Court 1980) (legislature does not specify abatement for visitation; court may not automatically reduce support)