Van Leuvan v. Carlisle, 322 Ga. App. 576

Mother challenges Fulton County court's temporary visitation order granting grandmother rights under OCGA § 19-7-3.
Trial court found grandparent visitation would harm the child’s health and welfare and was in the child’s best interests.
Mother argues lack of specific written findings of fact and improper evidentiary standard in support of the decision.
Mother contends the court erred in considering the guardian ad litem’s testimony and report.
Mother argues that the statute does not authorize temporary visitation orders.
Court vacates the order, remands for written findings, and addresses remaining issues on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Written findings and standard used	Mother asserts no specific findings or clear and convincing standard were shown.	Grandmother contends the findings were adequate under OCGA § 19-7-3 (c)(1).	Remand for written specific findings; need clear and convincing standard.
Admissibility of GAL testimony	Mother claims GAL testimony/report were improperly admitted.	GAL testimony admitted; mother waived objections by consenting to GAL appointment.	Waived objections; no reversible error on GAL admissibility.
Temporary visitation authority	Statute does not expressly authorize temporary orders for grandparent visitation.	Temporary orders are permissible under related custody statutes and definitions of custody.	Temporary visitation order authorized; remanded for new written order.

Rainey v. Lange, 261 Ga. App. 491 (Ga. App. 2003) (clear and convincing standard required for grandparent visitation evidence)
Cates v. Jamison, 301 Ga. App. 441 (Ga. App. 2009) (mandatory written findings of fact supported by evidence for visitation)
Srader v. Midkiff, 303 Ga. App. 514 (Ga. App. 2010) (attorney approval can waive appellate objections to form of order)
Luke v. Luke, 280 Ga. App. 607 (Ga. App. 2006) (specific findings and evidence standard in visitation orders)