Ward v. Ward, 289 Ga. 250

Dorene Ward and Richard Ward divorced in March 2007 with Richard awarded primary physical custody of their two children.
Dorene received substantial visitation and was ordered to pay child support.
In February 2008 Dorene sought contempt for Richard, sole custody, and potential support modification if custody were granted to her.
The trial court found Richard not in contempt, did not modify custody, increased Dorene's child support, and added a prohibition on Dorene having overnight male guests when children were present.
The court awarded Richard $10,000 in attorney fees.
Dorene appealed, challenging the visitation modification as overbroad and the attorney fees award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the amended visitation provision overbroad?	Ward	Ward	Yes; trial court abused discretion.
Is the attorney fees award properly grounded in statute or contract?	Ward	Ward	No; need statutory basis and findings; remand required.

Arnold v. Arnold, 275 Ga. 354 (2002) (court may restrict custodial rights to protect children if harm is shown)
Brandenburg v. Brandenburg, 274 Ga. 183 (2001) (visitation restrictions possible if conduct adversely affects children)
Moon v. Moon, 277 Ga. 375 (2003) (attorney fees generally not available absent statute or contract)
Roberts v. Tharp, 286 Ga. 579 (2010) (context for award of fees in contempt/modification actions)
McDonogh v. O'Connor, 260 Ga. 849 (1991) (fees considerations in divorce actions)
Simmons v. Simmons, 288 Ga. 670 (2011) (statutory basis for fees; considerations of financial circumstances)
Cason v. Cason, 281 Ga. 296 (2006) (need for explicit statutory basis and findings when awarding attorney fees)