The Georgia Court of Appeals upheld a lower court's ruling that found Shani Washington in contempt for violating a custody agreement with her ex-husband, Jermel Washington. The ruling, issued on June 4, 2026, affects the custody arrangements for their minor child, N. W., and emphasizes the importance of adhering to court orders in custody disputes.
The case began after the couple’s divorce in 2016, where Jermel was granted primary physical custody of their child. Shani later sought to modify the custody arrangement, but the trial court denied her request in February 2024, although it did modify the parenting plan. This modification included changing the locations for custody exchanges on non-school days.
In August 2024, Jermel filed a motion for contempt, claiming that Shani failed to comply with the custody exchange locations outlined in the February 2024 order. The trial court found her in civil contempt and awarded Jermel attorney fees. Shani appealed the ruling, arguing that the court erred in its decision and violated her due process rights.
Background
Shani and Jermel Washington share one child, N. W., and their custody battle has been ongoing since their divorce. Initially, Jermel received primary physical custody, while both parents maintained joint legal custody. Following the divorce, Shani sought to change the custody arrangement, leading to the February 2024 court order that denied her request but modified the parenting plan.
After the February ruling, Jermel alleged that Shani was not following the new custody exchange procedures. He claimed that she was taking their child to different locations instead of the agreed-upon places, which led him to file a contempt motion in August 2024. The trial court held a hearing in June 2025, where both parents testified about the custody exchanges.
The Ruling
The Court of Appeals of Georgia, in a decision led by Judge Mercier, affirmed the trial court's ruling, stating that Shani's actions constituted willful disobedience of the court's order. The court noted, "The essence of civil contempt ... is willful disobedience of a prior court order. If there is any evidence in the record to support the trial judge's determination that a party has willfully disobeyed a trial court's order, the decision of the trial court will be affirmed on appeal."
Shani argued that her non-compliance was due to anxiety and safety concerns stemming from her tumultuous relationship with Jermel. However, the court found that there was sufficient evidence to support the trial court's ruling that she willfully disobeyed the order by refusing to allow Jermel to pick up their child from her residence.
Impact
This ruling underscores the importance of adhering to court orders in custody cases. The court's decision could set a precedent for future cases involving custody disputes, emphasizing that claims of safety concerns must be substantiated with evidence. Parents involved in custody arrangements must understand that failure to comply with court orders can result in serious legal consequences, including contempt charges and financial penalties.
The ruling also highlights the responsibilities of pro se litigants, like Shani, who must follow court rules even when representing themselves. The court expressed concern over Shani's use of fictitious cases and quotes in her appeal, warning that such actions could lead to sanctions in the future.
What's Next
Shani Washington can appeal this decision to the Supreme Court of Georgia, but details on whether she plans to do so were not available in the court filing. Additionally, a motion she filed to modify the custody exchange locations is still pending in the trial court.