White v. Howard, 295 Ga. 210

George White (Husband) and Vanessa Howard (Wife) divorced in April 2007; the decree required Husband to (1) carry a $100,000 term life policy naming Wife beneficiary for 12 years, (2) pay half of Husband’s pension to Wife, and (3) make partial mortgage payments on property titled to Wife. The decree stated neither party was entitled to alimony and that the transfers were not alimony.
In July 2011, after Wife remarried, Husband filed pro se to terminate the three obligations as alimony terminated by remarriage; Wife moved to dismiss and sought attorney fees.
After representation change, Husband filed a complaint for modification; the trial court dismissed Husband’s claims, held the life-insurance obligation was a fixed property-type obligation (not modifiable), and awarded Wife $5,000 in attorney fees without stating a statutory basis.
Husband appealed; he did not challenge the rulings as to the pension split or mortgage payments.
The Supreme Court of Georgia reviewed whether the life-insurance obligation was property division/lump-sum alimony (nonmodifiable) or periodic alimony (modifiable and terminated by remarriage), and whether the attorney-fee award stated a statutory basis.

Issue	White's Argument	Howard's Argument	Held
Whether Husband’s obligation to maintain $100,000 term life insurance for 12 years was property division/lump-sum alimony or periodic alimony	The obligation was not modifiable because the decree labeled transfers "not alimony" and called the obligation fixed	The obligation was either property division or lump-sum alimony and therefore nonmodifiable	The life-insurance obligation was periodic alimony as a matter of law and terminated upon Wife’s remarriage because the decree did not expressly provide otherwise
Whether trial court erred in failing to state statutory basis for awarding Wife attorney fees	Husband argued the fee award lacked stated statutory basis and should be vacated/reconsidered	Wife sought fees but cited no statute at trial; urged upholding award	Fee award vacated; remand for reconsideration and, if awarded, require stated statutory basis and findings
Whether pension split and mortgage-payment obligations were modifiable	Husband sought termination/modification	Wife defended as equitable property division not subject to modification	Husband did not appeal these portions; those holdings affirmed

Rivera v. Rivera, 283 Ga. 547 (clarifies that labels do not control; distinguishes lump-sum alimony from periodic alimony)
Sapp v. Sapp, 259 Ga. 238 (life-insurance premium obligations contingent on spouse's life constitute periodic alimony)
Hawkins v. Hawkins, 268 Ga. 637 (obligation to pay life-insurance premiums for set years held periodic alimony)
Daopoulos v. Daopoulos, 257 Ga. 71 (remarriage terminates permanent alimony unless instrument expressly provides otherwise)
Moore v. Moore, 286 Ga. 505 (distinguishes fixed installment property-type awards from modifiable periodic alimony)
Daniel v. Daniel, 277 Ga. 871 (lump-sum/gross alimony characterized as final property settlement)
Douglas v. Cook, 266 Ga. 644 (OCGA § 19-6-19 does not authorize modification of equitable property-division judgments)