The Court of Appeals of Georgia has vacated a trial court's ruling in a child custody modification case involving Stephanie Cher McWilliams and John Christopher Meghrian. The court's decision, issued on November 2, 2026, affects how custody and support modifications are handled, particularly regarding attorney fees and restrictions on parental speech.

This case began when Father, John Meghrian, sought to modify the custody agreement he shared with Mother, Stephanie McWilliams, regarding their child born in 2008. The couple had previously agreed to joint physical custody in a consent order from May 2023. However, in August 2024, Father filed a petition seeking sole physical custody, child support, and attorney fees, claiming that Mother was in contempt of the consent order by not sharing costs related to their child's extracurricular activities and medical expenses.

The trial court held a temporary hearing in November 2024, which resulted in a temporary order granting Father physical custody and requiring Mother to pay $1,467 in monthly child support. The court based its decision on the monthly gross incomes of both parents, determining Father earned $8,249.29 and Mother earned $15,307.50. Following a final hearing in August 2025, the court issued a final order in November 2025 that maintained the child support amount and ordered Mother to pay Father $28,671.16 in attorney fees.

Mother appealed the trial court's final order, which included a permanent injunction preventing her from making disparaging remarks about Father on social media or through other means. The Court of Appeals reviewed the case to address several issues raised by Mother, including the attorney fees awarded to Father and the constitutionality of the speech restrictions placed on her.

The court ruled that the trial court erred in awarding attorney fees without specifying the statutory basis for the award. The opinion noted, "When there is more than one statutory basis for the attorney-fee award and neither the statutory basis for the award nor the findings necessary to support an award is stated in the order, the case is remanded for an explanation of the statutory basis for the award and the entry of any findings necessary to support it." This lack of clarity in the trial court's decision led to the vacating of the fee award.

Furthermore, the court addressed the speech restrictions imposed on Mother, stating that the final order included unconstitutional prior restraints on her speech. The court emphasized that the injunction directed Mother to cease all disparagement of Father, which raised significant constitutional concerns. The court found that Mother did not waive her right to challenge these restrictions, as she had raised the issue in her application for discretionary review.

In addition, the court found that the trial court had relied on outdated income evidence from the temporary hearing when determining child support. The ruling stated, "In Georgia, determining each parent’s monthly gross income is the first step that a court must take in calculating child support under our child support guidelines." The court emphasized that the trial court must clarify its reasoning for maintaining the child support amount without considering updated evidence.

Overall, the Court of Appeals vacated the trial court's orders regarding attorney fees, speech restrictions, and child support. The case was remanded for further proceedings to address the identified issues. The court's ruling highlights the importance of clearly articulating the statutory basis for attorney fees and ensuring that any restrictions on speech are constitutionally sound.

The outcome of this case may have broader implications for future custody modification cases in Georgia, particularly regarding how courts handle attorney fees and parental speech. The decision underscores the necessity for trial courts to provide clear justifications for their rulings and to adhere to constitutional standards when imposing restrictions on parents.

Looking ahead, the case may be subject to further appeals, but details were not available in the court filing regarding any pending related cases. The court's directive for further proceedings will likely lead to additional hearings to clarify the issues raised in the appeal.