Georgia Court of Appeals
Shienke Kimbro v. Tito Warren
A24A1389
January 9, 2025
Vacated & Remanded With Direction
Automated case summary
What the court decided
The Georgia Court of Appeals held that a trial court must find a material change in circumstances before modifying child custody arrangements. Because the trial court failed to make this threshold determination, the Georgia Court of Appeals vacated the order and remanded the case for further factual findings.