The survey year produced a wide array of appellate opinions with no discernible area of focus. Of particular interest were decisions holding that the relocation of a custodial parent is not alone grounds to change custody and that notice of trial by publication alone contravenes the due process rights of a pro se litigant in a divorce action in which custody of minor children is at issue. A resident can sue for divorce and an award of Georgia property even though the nonresident spouse has never been in the state. However, a resident cannot enforce a foreign divorce decree when the nonresident's only Georgia contact is via mail and telephone.
McGough, Barry B.
Mercer Law Review: Vol. 49
, Article 6.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol49/iss1/6