McGee, A. v. McDowell, J.

2025 Pa. Super. 52, 333 A.3d 383
CourtSuperior Court of Pennsylvania
DecidedMarch 4, 2025
Docket765 WDA 2024
StatusPublished
Cited by2 cases

This text of 2025 Pa. Super. 52 (McGee, A. v. McDowell, J.) 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
McGee, A. v. McDowell, J., 2025 Pa. Super. 52, 333 A.3d 383 (Pa. Ct. App. 2025).

Opinion

J-A29036-24

2025 PA Super 52

AUDRA MCGEE : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : JAMIE MCDOWELL : : Appellant : No. 765 WDA 2024

Appeal from the Order Entered May 23, 2024 In the Court of Common Pleas of Greene County Civil Division at 233 A.D. 2022

BEFORE: OLSON, J., LANE, J., and BENDER, P.J.E.

OPINION BY BENDER, P.J.E.: FILED: March 4, 2025

Jamie McDowell (Father) appeals from the trial court’s order denying his

exceptions to the order “affirm[ing] the September 25, 2023 order [sic1] as a

final custody order.” Order, 5/23/24. Due to procedural errors, we vacate

the order and remand for further proceedings.

CASE HISTORY

Father and Audra McGee (Mother) are the parents of an eight-year-old

son, C.M. (Child), who was born in January 2017. On March 29, 2022, Mother

filed a complaint for custody in which she sought primary physical custody of

Child.2 See Complaint for Custody, 3/29/22, at 2; id. at 3 (requesting the ____________________________________________

1 There is no order dated September 25, 2023.The Hearing Officer issued an opinion and recommended order dated September 28, 2023, and the trial court entered an order adopting the recommended order on October 2, 2023.

2 The Child Custody Act defines primary physical custody as the “right to assume physical custody of the child for the majority of time.” 23 Pa.C.S. § 5322(a). J-A29036-24

“court grant [Mother] PRIMARY physical and legal custody of [C]hild, C.M.,

and partial physical custody to [Father]”).

On February 7, 2023, the parties entered into a consent order which

provided for equally shared physical custody, on a “3-4/4-3 schedule,

alternating weekly.” Interim Custody Consent Order, 2/7/23, at 4. The

parties also agreed Child would “be enrolled in the Uniontown School District.”

Id. at 3. As the order was entered on an interim basis, the trial court

scheduled a status conference for July 24, 2023. On June 20, 2023, the court

“sua sponte continue[d] the [s]tatus [c]onference” to July 31, 2023. Order,

6/20/23.

At the July 31, 2023 status conference, Mother’s counsel stated:

At this point, things are in [Mother’s] opinion[,] going less than ideally for [C]hild and we’d like to proceed with a full hearing. [Father’s counsel] and I have touched base … to talk about some collateral issues under the [February 7, 2023 consent order]. I think the parties can move together working on those. But ultimately, I think the [c]ourt will have to make a final decision on physical custody.

N.T., 7/31/23, at 4. Father’s counsel confirmed, “for the most part[,] that’s a

correct recitation of what’s going on.” Id.

Mother’s counsel also reiterated that Mother was seeking primary

physical custody of Child. Id. at 6. Counsel stated that Mother “believes

[C]hild being with her primarily is in [C]hild’s best interest,” and Mother was

“seeking a reduction further than just three days a week for Father.” Id. at

-2- J-A29036-24

6-7. Both counsel agreed the parties were sharing physical custody “fifty-

fifty.” Id. They also agreed they would need one day for a trial. Id. at 7.

The trial court then addressed counsel and the parties, stating:

… I can’t imagine asking a stranger to decide my custody, but that’s why I’m here if you can’t [agree]. …

If you can’t, I won’t hold that against you. But I think [] counsel will tell you, even if you give up more than you think you should in an agreement, it’s almost always preferable t[o] going to a custody trial[, f]or many reasons. [Trial is] … contentious [and] stressful. It’s stressful on your child. ... So I would encourage you to keep working [on an agreement].

… [I]n my mind[, …] custody [] starts out as a fifty-fifty roughly, and then there can be reasons to [deviate]. And I’ve done it … many times. But in my mind, it starts off as something in that range and then if there[ are] reasons to adjust it, we’ll adjust it.

You both have experienced custody counsel. You need to listen to their advice. But, you know, bear in mind that the least stressful, best situation for you and your child is — ninety-nine percent [of the time] is to reach an agreement.

So I would encourage you to do that. Keep the lines of communication open and … you have to look at it from the standpoint of … I want to spend as much time with [Child] as I can, but I also have to do … what’s in [C]hild’s best interest[.] …

[I]f you’ve never been through a custody trial before, … it’s uncomfortable. And … you’re [giving information] to a stranger and you’re giving … custody of your child [to] a stranger to decide. And that is [my] job. Do it all the time. Not one of my favorite things to do. But very rarely do you hear people say, well, I really regret reaching an agreement. I really wish I would have went to a trial. … You hear the opposite of that.

And you know, custody is always open [to modification]. What you agree to today might need [to be] revisited in a year. You have a young child. You’re going to be dealing with this for a long time. So it’s never a final order. …

So lastly, I will tell you … and maybe your counsel already brought it up …, you have the option to have a record hearing in front of

-3- J-A29036-24

the Custody Hearing Officer [(Hearing Officer),] if you choose. This [case] is eligible for a hearing before me. So if you don’t both agree to go to a hearing in front of the [] Hearing Officer — a record hearing — it would be before me.

There are advantages and disadvantages to that. You can [discuss] those with your counsel. The chief disadvantage is some of your appeal rights are … I don’t want to say compromised, but limited. But the advantage is that you’ll get this settled much sooner. You’ll get on the calendar a lot quicker than you will with me. So it’s not going to be hanging out there.

So talk to your counsel…. [O]therwise, we will schedule it for a one-day custody trial. I have no idea when that will be, but it’s not going to be next week. It’s going to be a while, okay?

So in the meantime, keep those lines open. Hopefully you all can reach an agreement[,] … but if you don’t[,] and you don’t agree to go before the [H]earing [O]fficer for a record hearing, then we’ll see you here for that custody trial, okay?

Id. at 8-11.

According to Mother, the parties “both consented” to proceeding before

the Hearing Officer. Mother’s Brief at 13. Father does not disagree, although

he notes the “court gave the parties ‘the option’ of a hearing before the court

or a hearing before the [H]earing [O]fficer, even though the matter [involved]

primary custody.”3 Father’s Brief at 12-13. On August 1, 2023, the trial court

scheduled a hearing based on “the parties now wishing to proceed … before

the Hearing Officer.” Order, 8/1/23.

The parties appeared before the Hearing Officer on September 5, 2023.

On September 28, 2023, the Hearing Officer issued an opinion and

recommended order. The Hearing Officer recommended, inter alia, that the ____________________________________________

3 Father’s appellate counsel did not represent Father when he agreed to proceed before the Hearing Officer.

-4- J-A29036-24

parties exchange custody after school or at 5:00 p.m., with Mother having

primary physical custody four days a week (Thursday through Monday), and

Father having custody three days a week (Monday through Thursday). In

Father’s words, the Hearing Officer also “pulled [C]hild from [the school]

where he was attending first grade[,] and ordered that thereafter, [C]hild

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Bluebook (online)
2025 Pa. Super. 52, 333 A.3d 383, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcgee-a-v-mcdowell-j-pasuperct-2025.