Janisch, A. v. Janisch, H.

CourtSuperior Court of Pennsylvania
DecidedDecember 12, 2025
Docket2063 EDA 2025
StatusUnpublished

This text of Janisch, A. v. Janisch, H. (Janisch, A. v. Janisch, H.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Janisch, A. v. Janisch, H., (Pa. Ct. App. 2025).

Opinion

J-S41029-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

ANNA BERENIKE WILSON JANISCH : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : HALEH JENNIFER WILSON JANISCH : : Appellant : No. 2063 EDA 2025

Appeal from the Order Entered July 2, 2025 In the Court of Common Pleas of Chester County Civil Division at No(s): 2025-00292-CU

BEFORE: BOWES, J., BECK, J., and FORD ELLIOTT, P.J.E.*

MEMORANDUM BY BECK, J.: FILED DECEMBER 12, 2025

Haleh Jennifer Wilson Janisch appeals from the order entered by the

Chester County Court of Common Pleas denying her petition for relocation.

On appeal, Haleh argues that the trial court applied the incorrect standard in

evaluating the relocation and custody factors of the Child Custody Act. 1 As

we conclude that the trial court applied the appropriate standard in making its

decision and discern no abuse of discretion in the trial court’s denial of the

relocation petition, we affirm.

The trial court summarized the facts and procedural history of this case

as follows:

____________________________________________

* Retired Senior Judge assigned to the Superior Court.

1 23 Pa.C.S. §§ 5321-5340. J-S41029-25

Plaintiff, Anna Berenike Wilson Janisch (hereinafter “Anna”) and defendant, Haleh Jennifer Wilson Janisch (hereinafter “Haleh”) share one minor child – L.G.J, born [June 2021] (hereinafter “the child” and/or “L.G.J.”). Haleh is the child’s biological mother and Anna is the child’s adoptive mother. The parties separated in December 2023 and filed for divorce shortly thereafter.

On January 3, 2025, Haleh informed Anna of her intent to relocate to Massachusetts. Anna then filed her custody complaint on January 15, 2025, and subsequently filed her motion to prevent relocation on February 26, 2025. On March 25, 2025[,] an interim order was entered, granting the parties shared legal custody of [L.G.J.], with Haleh receiving primary physical custody. Anna receives one overnight visit per week, and daily visitation with the child after school. Anna’s custodial periods were to be supervised and she was ordered to use Soberlink prior to visiting with the child, [as a result of Anna’s issues with alcoholism, for which she is currently receiving treatment].

Following the entry of the March 25 interim order, Haleh refiled her notice of proposed relocation on April 2, 2025, in addition to filing her answer to Anna’s motion to prevent relocation. A hearing was conducted on June 9 and 10, 2025, including testimony from Haleh, Haleh’s sister – Mary Simon, Haleh’s parents – James and Jennifer Wilson, a mutually known family friend – Lauren Adams, Anna’s mother – Andrea Janisch, Anna’s friend and coworker – Paula Toburen, and Anna’s employer – Emma Brune.

Trial Court Opinion, 7/2/2025, at 2 (unnumbered, formatting modified).

On July 2, 2025, the trial court entered an order and opinion denying

Haleh’s petition for relocation and setting forth its analysis of the relocation

and custody factors of the Child Custody Act. See id. at 3-14. On July 31,

2025, Haleh timely appealed to this Court and contemporaneously filed her

statement of matters complained of on appeal pursuant to Pennsylvania Rule

of Appellate Procedure 1925.

-2- J-S41029-25

On August 18, 2025, this Court entered an order directing Haleh to show

cause as to the finality and appealability of the July 2, 2025 order because the

only order on the trial court docket as to Anna’s petition for custody was the

March 25, 2025 interim custody order. See Order, 8/18/2025. In response,

Haleh asserted that, following the order denying relocation, there is nothing

pending before the trial court, including “no pending dates, filed

modifications[,] or custody petitions.” Response to Rule to Show Cause,

8/27/2025, ¶¶ 7-11. Haleh also indicated that it was her “understanding that

upon informal request to [c]hambers, the [trial court] declined to issue any

further orders in this case after the issuance of the July 2, 2025 [relocation]

order.” Id. at n.1. Anna did not file a response. Thus, on September 2,

2025, this Court discharged the rule to show cause. See Order, 9/2/2025.

On October 1, 2025, however, Anna filed an application to dismiss the appeal

reraising the same issue this Court raised in its August 18, 2025 show cause

order. See Application to Dismiss, 10/1/2025. This Court subsequently

denied the application to dismiss without prejudice for Anna to raise the issue

in her appellate brief. See Order, 11/3/2025.

Our review of the record and the parties’ briefs supports Haleh’s

argument that the trial court does not have any intention of issuing further

orders in this case unless one of the parties initiates an additional action. As

there is currently a custody order in place, and the trial court’s order denying

Haleh’s petition to relocate represents the final resolution of that issue, we

-3- J-S41029-25

decline to quash Haleh’s appeal. Cf. S.S. v. T.J., 212 A.3d 1026, 1034 (Pa.

Super. 2019) (declining to address a trial court’s prior grant of relocation in

an appeal from a later filed petition for custody modification, explaining that

“a party may not use an appeal from the disposition of a petition for

modification of custody as a substitute for an appeal from an underlying order

for the purpose of relitigating matters pertaining to the underlying order[;] in

order to challenge a relocation order, the party must take a timely appeal from

the order”); see also Ketterer v. Seifert, 902 A.2d 533, 535-42 (Pa. Super.

2006) (addressing an appeal from the denial of a petition to relocate where

only a temporary custody order was in place at the time of the order denying

relocation). We now turn our attention to the merits of Haleh’s appeal.

Haleh presents the following issues for review:

1. The trial court erred and/or abused its discretion by determining that the testimony presented by [Haleh] “did not demonstrate any compelling reason for her to relocate,” that [she] “did not demonstrate to [the court] a compelling reason for relocation beyond close family ties which can provider her housing and childcare assistance,” and that “there was no compelling argument advanced to support relocation”; the standard in relocation cases is whether the relocation is in the best interest of the child, not whether the relocating party presents compelling testimony or argument.

2. The trial court erred and/or abused its discretion in failing to enter an order requiring the parties to attend coparent counseling.

Haleh’s Brief at 5.

The relevant scope and standard of review is as follows:

-4- J-S41029-25

In reviewing a custody order, our scope is of the broadest type and our standard is abuse of discretion. We must accept findings of the trial court that are supported by competent evidence of record, as our role does not include making independent factual determinations. In addition, with regard to issues of credibility and weight of the evidence, we must defer to the presiding trial judge who viewed and assessed the witnesses first-hand. However, we are not bound by the trial court’s deductions or inferences from its factual findings. Ultimately, the test is whether the trial court’s conclusions are unreasonable as shown by the evidence of record.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Ketterer v. Seifert
902 A.2d 533 (Superior Court of Pennsylvania, 2006)
M.J.M. v. M.L.G.
63 A.3d 331 (Superior Court of Pennsylvania, 2013)
S.S. v. K.F.
189 A.3d 1093 (Superior Court of Pennsylvania, 2018)
E.B. v. D.B.
209 A.3d 451 (Superior Court of Pennsylvania, 2019)
S.S. v. T.J.
212 A.3d 1026 (Superior Court of Pennsylvania, 2019)
White, A. v. Malecki, C.
2023 Pa. Super. 102 (Superior Court of Pennsylvania, 2023)
B.S.G. v. D.M.C.
2021 Pa. Super. 110 (Superior Court of Pennsylvania, 2021)
D.Q. v. K.K., J.M.
2020 Pa. Super. 249 (Superior Court of Pennsylvania, 2020)
Rogowski, S. v. Kirven, D.
2023 Pa. Super. 33 (Superior Court of Pennsylvania, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Janisch, A. v. Janisch, H., Counsel Stack Legal Research, https://law.counselstack.com/opinion/janisch-a-v-janisch-h-pasuperct-2025.