Land, R. v. Doran, K.

CourtSuperior Court of Pennsylvania
DecidedSeptember 18, 2023
Docket306 EDA 2023
StatusUnpublished

This text of Land, R. v. Doran, K. (Land, R. v. Doran, K.) 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
Land, R. v. Doran, K., (Pa. Ct. App. 2023).

Opinion

J-S23001-23

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

RICKY LAND : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : KAYLYNNE DORAN : No. 306 EDA 2023

Appeal from the Order Entered October 14, 2022 In the Court of Common Pleas of Pike County Civil Division at No(s): 147-2022- Civil

BEFORE: PANELLA, P.J., KUNSELMAN, J., and KING, J.

MEMORANDUM BY PANELLA, P.J.: FILED SEPTEMBER 18, 2023

Ricky Land (“Father”) appeals from the order issued October 14, 2022,

denying Father’s exceptions, and adopting the custody hearing officer’s report

and recommendations, thereby giving Kaylynne Doran (“Mother”) sole legal

and physical custody of the parties minor child (“Child”) 1. On appeal, Father

claims the trial court erred by conducting an ex parte custody hearing with

Mother without affording Father notice that he could request to be present at

the hearing, or otherwise have a meaningful opportunity to be heard. Mother

has not filed a brief on appeal. After careful review, we vacate and remand for

further proceedings.

____________________________________________

1 Child was one year old at the time Mother filed for custody and is currently

three years old. J-S23001-23

The parties are the natural parents of Child. As Father has been

incarcerated since October 2020, Child has resided with Mother since that

time. On February 3, 2022, Mother filed a complaint for custody seeking full

legal and physical custody of Child. After the parties were unable to reach an

agreement during a custody conference in March 2022, a custody hearing was

scheduled for May 23, 2022. Mother appeared and testified at the custody

hearing. Father failed to appear. After the hearing, the custody hearing officer

filed a report and recommendation in favor of Mother.

On August 3, 2022, Father filed an exception to the hearing officer’s

report and recommendation. Specifically, Father argued the custody hearing

was held in violation of his due process rights because the hearing was held

without Father present and without notice to Father of his right to attend.

After oral argument was held on Father’s exception, the trial court denied

Father’s exception and adopted the hearing officer’s report and

recommendation. This timely appeal followed.

Our scope and standard of review of child custody orders are settled:

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. We may reject the conclusions of the trial court only if they involve

-2- J-S23001-23

an error of law, or are unreasonable in light of the sustainable findings of the trial court.

S.T. v. R.W., 192 A.3d 1155, 1160 (Pa. Super. 2018) (citation omitted).

However, our review differs when an appellant presents a due process

challenge:

A question regarding whether a due process violation occurred is a question of law for which the standard of review is de novo and the scope of review is plenary.

Id. (citations omitted).

Father argues that the trial court erred by holding the custody hearing

outside his presence and failing to provide him with notice that he had a right

to request to be present at the hearing, or have the opportunity to be heard.

The trial court implicitly concedes that it did not provide Father with

explicit notice of his right to attend the hearing. See Trial Court Opinion,

2/15/2023, at 5. Nonetheless, the court contends that Father’s reliance on

S.T. is misplaced because the facts are distinguishable, and that in any event

Father was aware of his right to participate since he had exercised this right

in the past.

After reviewing the record, we disagree with the trial court on both

counts. We begin by noting that “the fact of a party’s incarceration places an

obligation on the court to safeguard his due process rights[.]” Vanaman v.

Cowgill, 526 A.2d 1226, 1227 (Pa. Super. 1987). As such, an imprisoned

person is due not only notice of a civil hearing, but must also be informed of

his right to attend. See S.T., 192 A.3d at 1162. Further, this is not just a

-3- J-S23001-23

question of whether Father waived his rights and interests in these

proceedings. Courts must be mindful that the paramount concern of custody

proceedings is the best interests of the child. See M.J.M. v. M.L.G., 63 A.3d

331, 334 (Pa. Super. 2013). And since “a determination of the child’s best

interests must have its basis in information[,]” precluding Father from

presenting evidence on Child’s best interests may violate Child’s rights as well.

See S.T., 192 A.3d at 1161.

The trial court contrasts the procedural history of S.T., where the

incarcerated parent initiated the proceedings, with the present case, where

Father is the respondent. However, none of the operative language in S.T.

relies on the distinction between a petitioner and a respondent:

In custody hearings, parents have at stake fundamental rights: namely, the right to make decisions concerning the care, custody, and control of their child.

Due process must be afforded to parents to safeguard these constitutional rights. Formal notice and an opportunity to be heard are fundamental components of due process when a person may be deprived in a legal proceeding of a liberty interest, such as physical freedom, or a parent's custody of her child. It is well settled that procedural due process requires, at its core, adequate notice, opportunity to be heard, and the chance to defend oneself before a fair and impartial tribunal having jurisdiction over the case. Due process is flexible and calls for such procedural protections as the situation demands.

S.T. v. R.W., 192 A.3d 1155, 1160-61 (Pa. Super. 2018) (citations and

internal quotation marks omitted) (emphasis in original). Further, Pa.R.Civ.P.

1930.4(f)(1)(ii) required that Father, as an incarcerated person, be provided

notice of his right to participate in the proceeding when Mother served him

-4- J-S23001-23

with original process in this domestic relations case. Father’s status as the

respondent here is not relevant to the question of whether the trial court was

required to give him notice of his right to be present for the hearing.

Similarly, Father’s presence at the prior conciliation conference does

not indicate whether Father was aware of his right to file the necessary

documents to ensure his presence at the full hearing. We note that it is not

clear, under S.T. and our existing Rules of Civil Procedure, whether the trial

court and incarcerated parents must continually re-engage in a notice/request

cycle for subsequent proceedings. In other words, it is possible that Father’s

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Related

Vanaman v. Cowgill
526 A.2d 1226 (Supreme Court of Pennsylvania, 1987)
M.J.M. v. M.L.G.
63 A.3d 331 (Superior Court of Pennsylvania, 2013)
S.T. v. R.W.
192 A.3d 1155 (Superior Court of Pennsylvania, 2018)

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