L.W. v. C.H.

CourtSuperior Court of Pennsylvania
DecidedJanuary 16, 2026
Docket1879 EDA 2025
StatusUnpublished
AuthorBeck

This text of L.W. v. C.H. (L.W. v. C.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
L.W. v. C.H., (Pa. Ct. App. 2026).

Opinion

J-S47044-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

L.W. : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : C.H. : : Appellant : No. 1879 EDA 2025

Appeal from the Order Entered July 14, 2025 In the Court of Common Pleas of Delaware County Civil Division at No(s): CV-2024-004462

BEFORE: PANELLA, P.J.E., OLSON, J., and BECK, J.

MEMORANDUM BY BECK, J.: FILED JANUARY 16, 2026

C.H. (“Father”) appeals pro se from the order granting L.W. (“Mother”)

sole legal custody and primary physical custody of the parties’ child, C.H.,

born April 2023, and granting Father partial physical custody. We affirm.

The trial court set forth the relevant factual and procedural history:

On or around May 20, 2024, Mother filed a [c]omplaint in [c]ustody, in which she alleged Father has a history of abuse, Protection from Abuse (“PFA”) violations, and a criminal record. This custody matter was originally assigned to the Honorable William C. Mackrides, who on September 23, 2024, following a pretrial conference, ordered the parties to submit to a custody evaluation. Mother participated in the custody evaluation, but Father did not. Judge Mackrides also ordered Father to submit to a psychological evaluation by Dr. Richard Roeder. Father never submitted to the psychological evaluation.

Following reassignment, this trial court scheduled the custody matter for trial to be held on June 11, 2025. About a week prior to trial, Father emailed court staff and asked for a new trial date, stating he had an eye infection that would preclude him from attending proceedings for the month of June. Father J-S47044-25

provided no medical documentation and when asked to do so, did not file a proper continuance form. Father also asked court staff how to transfer this matter to the Pennsylvania Superior Court. Still, the trial court continued the matter to July 9, 2025, and court staff informed Father of this in writing via email on June 2, 2025[,] as well as by mail in accordance with standard court procedures.

Close in time to the rescheduled trial, Father again contacted court staff and insisted he could not attend court on July 9, 2025. At trial, a court employee credibly testified that she made repeated efforts to communicate with Father over the phone and email, telling him he had to file a formal continuance if he wanted another continuance and providing him with the continuance form. The court employee credibly testified that she offered to accept medical documentation in lieu of a continuance form, but that Father did not provide medical documentation. The court employee credibly testified that Father refused to submit a continuance form and told her he would not be attending the trial date because his health was more important than attending.

At trial, Mother credibly testified as to Father’s history of domestic violence and to the fact that she completes all the parental duties for the Child. The trial court weighed the sixteen best interest factors and found that thirteen of those factors favored Mother, and that three factors (preference of the child, proximity of the houses, and any other relevant factor) favored no party. …

The trial court then considered what type of partial physical custody for Father, if any, was appropriate. Notably, the custody evaluator recommended that the trial court grant Mother sole physical custody, with no visitation at all for Father. The trial court reviewed Kaydens Law, which indicates that if a court finds an ongoing risk of abuse to a child by a preponderance of the evidence, a rebuttable presumption allowing only supervised physical custody applies. See 23 Pa.C.S. § 5323(e.1). Based on its crediting Mother’s testimony regarding Father’s history of domestic violence, the trial court found the presumption applies and granted only supervised physical custody to Father. Father’s appeal followed.

Trial Court Opinion, 8/26/2025, 1-3 (some citations omitted).

-2- J-S47044-25

Father filed a timely notice of appeal but did not contemporaneously file

his concise statement of errors complained of on appeal as required. See

Pa.R.A.P. 1925(a)(2)(i). On July 22, 2025, the trial court ordered Father to

file a concise statement of matters complained of on within twenty-one days,

and Father complied.1

At the outset, we note that Father’s brief fails in many respects to

comply with our Rules of Appellate Procedure. It does not include a statement

of questions presented, the “Order or other determination in question,” and

“Statement of both the scope of review and the standard of review,” all of

which are required portions of his appellate brief. See Pa.R.A.P. 2111(a),

2116(a). Furthermore, Father’s entire argument section, recited in its entirety

below, consists of bald claims of due process violations and judicial

misconduct:

I. Procedural Due Process Violations Due process requires notice and an opportunity to be heard. Armstrong v. Manzo, 380 U.S. 545 (1965). [Father’s] timely communication was ignored; judgment was entered in absentia. Such conduct denies fundamental fairness.

II. Substantive Due Process Violations The right to custody and companionship of one’s child is a protected liberty interest. Santosky v. Kramer, 455 U.S. 745 ____________________________________________

1 As the parties suffered no prejudice by Father’s failure to file his concise statement with his notice of appeal, we decline to find Father’s claims waived on this basis. See In re K.T.E.L., 983 A.2d 745, 748 (Pa. Super. 2009) (declining to find waiver based on failure to file a 1925(b) statement contemporaneously with a children’s fast track appeal absent prejudice to the parties).

-3- J-S47044-25

(1982). The court acted without compelling reason and therefore abused its discretion.

III. Equal Protection and Judicial Misconduct [Father] was treated differently from similarly situated litigants. Clerks and the presiding judge displayed bias and unprofessional behavior contrary to Canon 2 of the Pennsylvania Code of Judicial Conduct. This eroded the appearance of impartiality required by law.

Father’s Brief at 2 (unnumbered).

Father’s claims do not include meaningful discussion or developed

analysis of the issues he seeks to raise. See Pa.R.A.P. 2119(a) (argument

must contain “such discussion and citation of authorities as are deemed

pertinent”); see also Coulter v. Ramsden, 94 A.3d 1080, 1089 (Pa. Super.

2014) (stating “[m]ere issue spotting without analysis or legal citation to

support an assertion precludes our appellate review of [a] matter”) (citation

omitted). Although we are “willing to liberally construe materials filed by a

pro se litigant, pro se status confers no special benefit upon the appellant.”

Jordan v. Pennsylvania State Univ., 276 A.3d 751, 761 (Pa. Super. 2022)

(citation, brackets, and emphasis omitted). “This Court will not act as counsel

and will not develop arguments on behalf of an appellant.” Coulter v.

Ramsden, 94 A.3d 1080, 1088 (Pa. Super. 2014).

Despite our best efforts, we are unable to discern what Father is

challenging in his third issue on appeal. He fails to identify the “similarly

situated litigants” he alludes to or explain how he was “treated differently.”

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Related

Armstrong v. Manzo
380 U.S. 545 (Supreme Court, 1965)
Santosky v. Kramer
455 U.S. 745 (Supreme Court, 1982)
In the Interest of: S.L., a Minor Appeal of: J.B.
202 A.3d 723 (Superior Court of Pennsylvania, 2019)
Commonwealth v. Preston
904 A.2d 1 (Superior Court of Pennsylvania, 2006)
In re K.T.E.L.
983 A.2d 745 (Superior Court of Pennsylvania, 2009)
Umbelina v. Adams
34 A.3d 151 (Superior Court of Pennsylvania, 2011)
Coulter v. Ramsden
94 A.3d 1080 (Superior Court of Pennsylvania, 2014)
S.T. v. R.W.
192 A.3d 1155 (Superior Court of Pennsylvania, 2018)
Com. v. Stauffenberg, D.
2024 Pa. Super. 131 (Superior Court of Pennsylvania, 2024)
Jordan, E. v. PSU
2022 Pa. Super. 84 (Superior Court of Pennsylvania, 2022)

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Bluebook (online)
L.W. v. C.H., Counsel Stack Legal Research, https://law.counselstack.com/opinion/lw-v-ch-pasuperct-2026.