Shani Washington v. Jermel Washington

── Shani Washington v. Jermel Washington ── Court: Court of Appeals of Georgia Date: June 04, 2026 Category: General FIFTH DIVISION BROWN, C. J., RICKMAN, P. J., and MERCIER, J. NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.gov/rules June 4, 2026 In the Court of Appeals of Georgia A26A0506. WASHINGTON v. WASHINGTON. MERCIER, Judge. Shani Washington (“Mother”) and Jermel Washington (“Father”), who share one minor child, N. W., were divorced in 2016, and Father was given primary physical custody of N. W. Mother later filed a motion to modify custody, which the trial court denied in a February 2024 order, but it modified the parenting plan. In August 2024, Father filed a motion for contempt asserting, inter alia, that Mother had failed to follow the February 2024 order regarding exchange locations for non-school days. The trial court found Mother in civil contempt of the February 2024 order and awarded Father attorney fees under OCGA § 19-6-2. Mother filed this pro se appeal of the trial court’s order, arguing that it erred by finding her in contempt, that her due process rights were violated, that the trial court erred by excluding evidence, that the award of attorney fees was improper, that the order was improper and that cumulative error required reversal.1 As Mother has failed to show error, we affirm the trial court’s order.2 Although the parties shared joint legal custody of N. W., the trial court awarded primary physical custody to Father and visitation to Mother. The parenting plan provided that non-school day exchanges of custody would occur at the Vinings Vintage Clubhouse or Mother’s house. 1 As an initial matter, we are troubled by Mother’s citation to fictitious cases and fictitious quotations throughout her appellate brief. “Such ‘hallucinated’ cases are typically a hallmark of the irresponsible use of regenerative artificial intelligence (A.I.) in legal drafting.” Slay v. Ross, 379 Ga. App. 1, 1 (927 SE2d 569) (2026). While Mother is pro se, she is nonetheless required to follow the rules of this Court, and we caution her that any future filings in this Court containing fictitious cases and/or fictitious quotations may result in the imposition of sanctions against her. See Court of Appeals Rule 7(e)(2) (“The panel of the Court ruling on a case, with or without motion, may by majority vote to impose a penalty not to exceed $10,000 against any party and/or a party’s counsel in any civil case in which there is a direct appeal, application for discretionary appeal, application for interlocutory appeal, or motion that is determined to be frivolous.”); Modi v. India-Am. Cultural Ass’n, 367 Ga. App. 572, 574(2) (886 SE2d 378) (2023) (“Although [Appellant] is proceeding pro se, [she] is not relieved of [her] obligation to conform to this Court’s rules.”) (quotation marks omitted). 2 As we have jurisdiction of this appeal pursuant to OCGA § 5-6-34 (a)(11), we hereby deny the Father’s motion to dismiss. 2  Mother filed a motion to modify custody, and the trial order entered an order on February 13, 2024, which denied her motion to modify custody but modified the parenting plan, which included changing the exchange location for non-school days to both parents’ houses. On August 19, 2024, Father filed a motion for both civil and criminal contempt alleging, inter alia, that Mother violated the February 2024 order by moving the non- school day exchange location, and he requested attorney fees.3 The trial court held a hearing on June 4, 2025, regarding the Father’s motion for contempt, and both parents testified. Father testified that Mother failed to follow the cus