(Code 1981, §19-6-34, enacted by Ga. L. 1995, p. 603, § 3; Ga. L. 2006, p. 583, § 5/SB 382.)
Editor's notes.- Ga. L. 2006, p. 583, § 10(b)/SB 382, not codified by the General Assembly, provides: "Sections 1 through 7 of this Act shall become effective on January 1, 2007, and shall apply to all pending civil actions on or after January 1, 2007."
Law reviews.- For article on 2006 amendment of this Code section, see 23 Ga. St. U.L. Rev. 103 (2006).
JUDICIAL DECISIONS
Premium properly included as part of support.
- Mother's premium for life insurance for her two minor children, custody of whom was awarded to the father, was counted as a part of the support ordered pursuant to the provisions of O.C.G.A. § 19-6-15 of the Georgia Child Support Guidelines. Moon v. Moon, 277 Ga. 375, 589 S.E.2d 76 (2003).
Premium excluded from guidelines.
- Trial court did not abuse the court's discretion by declining to consider the cost of the life insurance in calculating a parent's child support obligation because the evidence indicated that a parent's company, rather than the parent, paid the premiums on the parent's life insurance policies. Simmons v. Simmons, 288 Ga. 670, 706 S.E.2d 456 (2011).
Order that child past age of majority be named beneficiary of life insurance policy improper.
- Order requiring the husband to maintain a life insurance policy with the four children of the marriage named as equal beneficiaries was improper because the couple's eldest child had reached the age of majority when the judgment was entered, and there was no evidence of a voluntary obligation by the husband to assume a support obligation that exceeded the husband's legal duty. Mongerson v. Mongerson, 285 Ga. 554, 678 S.E.2d 891 (2009), overruled on other grounds, 288 Ga. 670, 706 S.E.2d 456 (2011).
Parent required to maintain life insurance benefiting child.
- Trial court did not abuse the court's discretion in requiring a parent to maintain life insurance for the benefit of the child and by ordering the creation of a trust for any life insurance proceeds; O.C.G.A. § 19-6-34(a) does not limit the value of any life insurance to the future child support obligation of the parent, and the amount is within the trial court's discretion. Simmons v. Simmons, 288 Ga. 670, 706 S.E.2d 456 (2011).
Trial court did not err by ordering a husband's child support obligation to be secured by a life insurance policy for the support of the minor children because the trial court had discretion to require a parent, without the parent's agreement, to provide life insurance for the support of minor children pursuant to O.C.G.A. § 19-6-34. Jarvis v. Jarvis, 291 Ga. 818, 733 S.E.2d 747 (2012).