Jennifer Daugherty v. Matthew Woodard

Court of Appeals
of the State of Georgia

ATLANTA,____________________
May 05, 2026

The Court of Appeals hereby passes the following order:

A26A1874. JENNIFER DAUGHERTY v. MATTHEW WOODARD.

Jennifer Daugherty filed this action against Matthew Woodard, seeking to hold
him in contempt of his child support obligation under the parties’ divorce decree. The
trial court issued an order finding Woodard in contempt, but finding that the court
could not calculate his arrearage. The court also issued an order awarding Woodard
attorney fees. Daugherty then filed this direct appeal. We lack jurisdiction.
Appeals from judgments or orders in domestic relations cases, including orders
“holding or declining to hold persons in contempt,” must be made by application for
discretionary appeal. See OCGA § 5-6-35(a)(2), (b). See also Russo v. Manning, 252
Ga. 155, 156 (312 SE2d 319) (1984) (“A judgment of contempt regarding a domestic
relations decree is appealable only by application for discretionary appeal.”); Booker
v. Ga. Dept. of Human Resources, 317 Ga. App. 426, 427 (731 SE2d 110) (2012) (an
action in which the “underlying subject matter is a father’s obligation to provide child
support” is “a domestic relations case subject to review only by application”).
“Compliance with the discretionary appeals procedure is jurisdictional.” Hair
Restoration Specialists v. State of Ga., 360 Ga. App. 901, 903 (862 SE2d 564) (2021).
Thus, Daugherty’s failure to follow the discretionary appeals procedure deprives us
of jurisdiction over this appeal, which is hereby DISMISSED.

Court of Appeals of the State of Georgia
Clerk’s Office, Atlanta,____________________
05/05/2026
I certify that the above is a true extract from
the minutes of the Court of Appeals of Georgia.
Witness my signature and the seal of said court
hereto affixed the day and year last above written.

, Clerk.