A.H. v. C.M., 58 A.3d 823

Mother appeals custody order denying her petition for de novo review of the parenting coordinator decision, entered after an incident at a school recital in 2012.
Parenting coordinator order (6/9/2008) provided for court review of coordinator decisions, with burden on moving parent.
Coordinator Audrey Woloshin found Mother violated the coordinator's communication policy; Father supported the coordinator's involvement.
Trial court conducted a brief conference on 4/25/2012, limited Mother to four minutes, and denied review without a de novo hearing.
Mother timely appealed; Act applicability established because the custody proceeding commenced after 1/24/2011, triggering Act provisions.
Court reverses and remands for de novo review and a hearing on the record within 30 days.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether de novo review is required for parenting-coordinator decisions	Mother seeks de novo review per Yates	Trial court relied on policy and denied separate hearing	De novo review required; trial court must hold de novo hearing
Whether the trial court complied with Yates in reviewing the coordinator's decision	Mother asserts due process requires de novo hearing	Court allowed argument but not a de novo hearing	Trial court must conduct de novo review and not substitute coordinator’s judgment
What remedy on remand is appropriate	Mother should receive proper de novo hearing	No further comment beyond standard review	Remand with ordered de novo hearing and detailed coordinator-order synthesis

Yates v. Yates, 963 A.2d 535 (Pa. Super. 2008) (de novo review required for parenting-coordinator decisions; due process concerns)
Ketterer v. Seifert, 902 A.2d 533 (Pa. Super. 2006) (context on custody discretion and appellate deference)
Jackson v. Beck, 858 A.2d 1250 (Pa. Super. 2004) (custody proceedings and appellate review principles)
Commonwealth v. Druce, 848 A.2d 104 (Pa. 2004) (canons of judicial conduct referenced for normative standards)