Ashley Nicole Geiger v. Patti Allmond

CourtCourt of Appeals of Georgia
DecidedMay 23, 2024
DocketA24A0062
StatusPublished

This text of Ashley Nicole Geiger v. Patti Allmond (Ashley Nicole Geiger v. Patti Allmond) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ashley Nicole Geiger v. Patti Allmond, (Ga. Ct. App. 2024).

Opinion

THIRD DIVISION DOYLE, P. J., HODGES and WATKINS, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

May 23, 2024

In the Court of Appeals of Georgia A24A0061, A24A0062. GEIGER v. ALLMOND (two cases).

DOYLE, Presiding Judge.

In these consolidated cases, Ashley Geiger (“the Mother”) appeals from an

order granting permanent custody of her two minor children to Patti Allmond, the

children’s paternal grandmother (“the Grandmother”). She contends that the

evidence was insufficient to support the custody award under the standard in OCGA

§ 19-7-1 (b.1). Based on the record before us, we agree.

When reviewing an order in a child custody case, we view the evidence in the light most favorable to the trial court’s decision. We will not set aside the trial court’s factual findings if there is any evidence to support them, and we defer to the trial court’s credibility determinations. We review de novo, however, the legal conclusions the trial court draws from the facts.1

So viewed, the record shows that the Mother was in a relationship with the

children’s father, Travis Wells (“the Father”), for 22 years, but they never married.

Throughout this time, they were “toxic from the start” and had difficulties in their

relationship. Despite this, they had two children, a son born in 2010, and a daughter

born in 2014. The Mother was the primary caregiver.

Eventually, the relationship soured to the point that in April 2021, the Mother

fled what she called a verbally and emotionally abusive relationship and left the family

home with the children, moved in with the maternal grandmother in Florida,

approximately six or seven hours away by car. Soon thereafter, the Father filed a

legitimation petition, and in July 2021, a consent order on legitimation was entered,

granting the Father primary physical custody with the parents having joint legal

custody, and the Mother having weekend visitation once per month. The Mother was

pro se at the time.

1 (Punctuation omitted.) Williams v. Phillips, 368 Ga. App. 371 (890 SE2d 125) (2023), quoting Mashburn v. Mashburn, 353 Ga. App. 31, 32 (836 SE2d 131) (2019). 2 By November 2021, the Father had denied the Mother visitation, so the Mother

filed a motion for contempt, seeking to enforce her visitation rights.2 The following

month, the Father filed an emergency petition to modify custody and suspend the

Mother’s visitation based on his suspicion that the daughter had been sexually

abused.3 The Father had learned that the maternal grandmother’s boyfriend was living

in the house where the Mother was staying , the boyfriend had a conviction for sexual

battery of a minor, and the couple’s daughter had complained of a molluscum

infection on various parts of her body. The daughter was physically examined and a

forensic interview was conducted; no allegations of abuse were disclosed or

confirmed. The physical exam concluded that the molluscum was common in children

and of an indeterminate cause, and the Mother explained that the daughter had

suffered from it prior to any interaction with the boyfriend.

Following this process, the Mother was temporarily awarded custody of the

children, but eventually offered to give custody of the children to the Grandmother,

who ultimately, due to the order awarding the Father temporary custody in July 2021,

2 That action was docketed in this Court as Case No. A24A0061. 3 That action was docketed in this Court as Case No. A24A0062 and has been consolidated with Case No. A24A0061. 3 became the children’s primary caregiver for the approximate year and a half before the

final hearing.

In March 2022, the court appointed a guardian ad litem (“GAL”), and shortly

before the GAL’s report was issued, the Grandmother filed a motion to intervene and

a petition to obtain primary custody of the children.4 In December 2022, the trial court

held an evidentiary hearing on the Grandmother’s motion to intervene and petition

for custody, as well as the Mother’s contempt motion and the Father’s motion to

modify custody. During the hearing, the GAL testified and recommended that

primary physical custody be awarded to the Mother; the Mother, Father, and

Grandmother also testified. Thereafter, the trial court entered an order granting the

Grandmother’s motion to intervene, awarding permanent custody to the

Grandmother with visitation to the Mother and Father on alternating weekends.

The Mother now appeals and argues that the evidence was insufficient to

support the custody award to a third-party under OCGA § 19-7-1 (b.1). Based on the

record before us, we agree.

OCGA § 19-7-1 (b.1) provides as follows:

4 That action is a part of Case No. A24A0061. 4 Notwithstanding . . . any other law to the contrary, in any action involving the custody of a child between the parents or either parent and a third party limited to grandparent [and other relatives], parental power may be lost by the parent . . . if the court hearing the issue of custody, in the exercise of its sound discretion and taking into consideration all the circumstances of the case, determines that an award of custody to such third party is for the best interest of the child or children and will best promote their welfare and happiness. There shall be a rebuttable presumption that it is in the best interest of the child or children for custody to be awarded to the parent or parents of such child or children, but this presumption may be overcome by a showing that an award of custody to such third party is in the best interest of the child or children. The sole issue for determination in any such case shall be what is in the best interest of the child or children.

Thus, the Code establishes

a rebuttable presumption that it is in the best interest of a child to award custody to the parent of the child. To overcome this presumption, a third-party relative must show, with clear and convincing evidence, that the child will suffer either physical harm or significant, long-term emotional harm if custody is awarded to the parent. In addressing the issue of harm, trial courts must consider a variety of factors beyond biological connection or generalized notions of parental fitness. They also must consider the parental needs and the circumstances of the child in question, including (1) who are the past and present caretakers of the child or children; (2) with whom has the child or children formed psychological bonds and

5 how strong are these bonds; (3) have the competing parties evidenced interest in, and contact with, the child or children over time; and (4) are there any unique medical or psychological needs of the child or children.5

With respect to the harm in this context, it must meet the above standard and

not be

merely social or economic disadvantages.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Clark v. Wade
544 S.E.2d 99 (Supreme Court of Georgia, 2001)
Stone v. Stone
774 S.E.2d 681 (Supreme Court of Georgia, 2015)
Strickland v. Strickland
783 S.E.2d 606 (Supreme Court of Georgia, 2016)
In the INTEREST OF K.M., a Child.
811 S.E.2d 505 (Court of Appeals of Georgia, 2018)
JEWELL v. MCGINNIS Et Al.
816 S.E.2d 683 (Court of Appeals of Georgia, 2018)
Floyd v. Gibson
788 S.E.2d 84 (Court of Appeals of Georgia, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Ashley Nicole Geiger v. Patti Allmond, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ashley-nicole-geiger-v-patti-allmond-gactapp-2024.