My wife and I both have been residents of Georgia for 3 years. She is a independent contracter who received a 1099misc from a California company where she received $19,151.62. We have filed our federal and state returns already. Does she have to file a California NR return. We included this info on our federal return.

If she has NOT been working or living in California, there is NO requirement for her to file a California return, as California has NO LEGAL STANDING to tax her on that income.