Grove v. Grove

Summary

The Georgia Supreme Court affirmed a divorce judgment awarding paternal grandparents visitation as a substitute for the father’s visitation schedule. The court held that the wife waived objections to the grandparents’ failure to intervene and to the absence of written findings of fact by failing to raise those issues below and by approving the judgment as to form.

Holdings

1. Wife waived any objection based on the grandparents' failure to intervene because she did not raise that objection in the trial court and instead participated in litigating the visitation issue.
2. Wife was estopped from challenging the absence of findings of fact because her counsel approved the final judgment as to form and she did not object to the lack of findings in the trial court.

Questions Presented

1. Whether the trial court erred by awarding the paternal grandparents visitation when they had not filed a petition to intervene.
2. Whether the final judgment had to be reversed because it lacked the specific written findings of fact required for a grandparent-visitation award.

Disposition

affirmed