Bishop v. Baumgartner: Visitation denied to alcoholic father may be changed with a custody modification action based on an improvement in conduct.
By Sarah McCormack, Family Lawyer
Where was visitation properly denied to father due to alcohol and alcohol abuse and other issues, nothing barred father from later coming back and claiming an improvement in his conduct that could constitute the requisite change of circumstances that would support a custody modification action.
Sarah McCormack grew up in Atlanta, Georgia, before receiving her undergraduate degree at the University of Virginia and her law degree at the University of North Carolina, Chapel Hill. She has participated in two Georgia appellate decisions: Kean v. Marshall, 294 Ga. App. 459 (2008), and RTS Landfill, Inc. v. Appalachian Waste Systems, LLC, 267 Ga. App. 56 (2004). Ms. McCormack shares her household with her husband, Kevin McCormack, a Senior Web Producer for Turner Sports, her son, Dylan, and her daughter, Lark. She is with the firm of Kessler & Solomiany LLP, in Georgia.