Tomkosky, C. v. Critchfield, R.

CourtSuperior Court of Pennsylvania
DecidedOctober 7, 2025
Docket103 WDA 2025
StatusUnpublished

This text of Tomkosky, C. v. Critchfield, R. (Tomkosky, C. v. Critchfield, R.) 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
Tomkosky, C. v. Critchfield, R., (Pa. Ct. App. 2025).

Opinion

J-A19016-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

CHRISTIAN TOMKOSKY : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellant : : : v. : : : RACHEL CRITCHFIELD : No. 103 WDA 2025

Appeal from the Order Entered December 30, 2024 In the Court of Common Pleas of Cambria County Civil Division at No: 2023-5203

BEFORE: BOWES, J., STABILE, J., and BENDER, P.J.E.

MEMORANDUM BY STABILE, J.: FILED: October 7, 2025

Appellant, Christian Tomkosky (“Father”), appeals from the December

30, 2024, order granting him partial custody of his seven-year-old child, A.T.

A.T. was born to Father and Appellee, Rachel Critchfield (“Mother”), in 2017.

Upon review, we affirm the trial court’s order.

The parties were never married. Their relationship, which both describe

as abusive and toxic, began 2009, when they were in high school, and ended

in 2020. Their relationship ended after a violent altercation in April of 2020.

Father was arrested and charged with aggravated assault and related offenses

afterward, but Mother chose not to pursue the charges.

After their break-up the parties attempted to share custody of A.T.

without court involvement. During that time, Mother had primary physical

custody, with Father having custody on weekends and at other times by J-A19016-25

agreement. Mother and A.T. live in Johnstown with Mother’s parents

(“Maternal Grandparents”). Father lives in Johnstown with his wife, Rachel

Tomkosky (“Stepmother”), whom he married in 2023. As of the trial court’s

order, A.T. was in second grade at Divine Mercy Catholic School. The parties

and Maternal Grandparents share the cost of tuition.

Father initiated this action with a complaint for custody on December

19, 2023. Father sought primary physical custody and sole legal custody of

A.T. Pursuant to a March 1, 2024, interim order, the parties had shared legal

custody and Mother had primary physical custody of A.T. In the order on

appeal, the trial court granted the parties shared legal custody, with Mother

having primary physical custody of A.T. and Father having partial physical

custody on a seven-week rotating schedule. The order on appeal resulted in

a slight increase to Father’s custody of A.T. This timely appeal followed.

Father raises seven assertions of error:

I. Did the trial court err in entering an unduly cumbersome seven (7) week custody schedule that is not workable for either party?

II. Did the trial court commit an error of law in awarding [Father] partial physical custody, and [Mother] primary physical custody when presented with clear and uncontroverted evidence that Mother is not able to exercise primary physical custody, which is against the best interest of [A.T.] as Mother is a largely absent parent?

III. Did the trial court commit an error of law in prioritizing the relationship of third parties over the relationship of the parent with the minor child?

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IV. Did the trial court fail to include a summer schedule or specific holiday schedule in the [custody order]?

V. Did the trial court commit an error of law in failing to consider the severity of the medical neglect, dental neglect, and educational deficiencies of the minor child in Mother’s primary custody?

VI. Did the trial court rely on blatantly false information presented by Mother despite the physical evidence controverting the same being admitted?

VII. Did the trial court err in characterizing Father’s behavior as revengeful when there was no evidence presented by either party of the same?

Father’s Brief at 4-5.

We conduct our review in accordance with the following:

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

With any child custody case, the paramount concern is the best interests of the child. This standard requires a case-by-case assessment of all the factors that may legitimately affect the physical, intellectual, moral and spiritual well-being of the child.

M.J.M. v. M.L.G., 63 A.3d 331, 334 (Pa. Super. 2013), appeal denied, 68

A.3d 909 (Pa. 2013). We observe that 23 Pa.C.S.A. § 5328 expressly

mandates the consideration of a list of relevant factors, giving weight to those

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that affect the child’s safety. 23 Pa.C.S.A. § 5328(a). Thus, the factors set

forth in § 5328(a) are not to be viewed in isolation. We therefore begin with

a summary of the trial court’s analysis of § 5328(a).

The trial court found that § 5328(a)(2.2)1 favored Mother because of

Father’s previous violent assault of her. Trial Court Opinion 12/23/24, at 19-

20. Regarding the assault, the trial court noted the following evidence:

Father claims Mother was the instigator who refused to leave him alone when he attempted to separate himself from Mother in order to reduce tension. Mother claims that Father caused the situation to escalate by refusing to communicate with her. Essentially, Mother believed that Father was cheating on her with other women on this particular day because he was not responding to her and she could not locate him. When Mother finally confronted Father, he did not dispute Mother’s claims. Mother did confront Father in a garage area where the parties lived. This altercation resulted in multiple separate confrontations with Mother going to the garage and then going back to the parties’ residence. During these confrontations, both parties yelled at each other, hit one another, and threw things at one another. During the final confrontation, Mother appeared at the garage and brandished a gun. Father confiscated the gun from Mother and then assaulted Mother and burned her belongings in the parking lot. As the final part of the confrontation, it is alleged that Father shot the gun either in the air or in the direction of Mother in the window of the parties’ home while he was burning Mother’s belongings in the parking lot. The altercation resulted in the police being called and Father being arrested[.]

Trial Court Opinion, 12/23/24, at 3-4, ¶ 11 (footnote omitted).

____________________________________________

1 We are cognizant that § 5328 has been amended effective August 29, 2025. The statutory citations in this memo are to the version of the statute in effect at the time the trial court entered the order on appeal.

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Under § 5823(2.3), the trial court found, based on the parties’ past

behavior, that Mother was more likely to encourage continued contact

between the parties than Father. “While both parties clearly do not like one

another, the record establishes that Mother has voluntarily permitted Father

to have increased time with A.T. while Father appears desirous to take time

away from Mother.” Id. at 20. The court continued,

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Tomkosky, C. v. Critchfield, R., Counsel Stack Legal Research, https://law.counselstack.com/opinion/tomkosky-c-v-critchfield-r-pasuperct-2025.