Adams v. Heffernan
Adams v. Heffernan, 217 Ga. 404, 122 S.E.2d 735 (Ga. 1961), was a habeas corpus proceeding involving the custody of minor children.
The Supreme Court of Georgia held it to be "settled law in this State that the doctrine of res judicata applies in child custody cases, and that when an award has been made the judge may thereafter exercise a discretion as to the custody of the children only so far as there may be new and material conditions and circumstances substantially affecting the interest and welfare of the children." Id. at 736.