D.R.L. v. K.L.C., 216 A.3d 276

Child born 2008; parents separated when child was two; biological father died in 2016; adoptive father adopted child in 2017.
Prior to litigation, maternal custody was primary; paternal grandparents had regular informal visitation every other weekend, holidays, and summer vacation.
Paternal grandparents filed for partial custody (Oct. 2016); parties entered a January 20, 2017 Custody Consent Order giving mother primary physical and sole legal custody and specified grandparent visitation.
Grandparents sought modification (Dec. 2017). A Custody Conference Officer (CCO) heard testimony (including the child) and recommended keeping the status quo, adding two nonconsecutive summer weeks for grandparents; trial court adopted recommendation with minor summer adjustments.
Grandparents appealed, arguing CCO/trial court bias, inadequate consideration of best‑interests and grandparents’ history with the child, and erroneous treatment of "interference" as time away from the mother.
Superior Court affirmed: trial court/C C O conducted the statutorily required best‑interest analysis (23 Pa.C.S. §5328), credited the child’s expressed preference for the current schedule, and found expansion would interfere with parental/ sibling relationships.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. CCO/trial court bias	CCO biased against grandparents (comment about keeping memory of biological father; burden language)	CCO remarks were neutral/contextual; burden on grandparents to show best interest/no interference	No bias; comments understandable; grandparents bear burden to prove custody change
2. Best‑interests analysis omitted or inadequate	Court failed to consider grandparents’ long history and weight their role appropriately	Court thoroughly considered all 16 §5328 factors and child’s preference; grandparents already have substantial time	Affirmed; court sufficiently analyzed §5328 factors and relied on competent evidence
3. Interference mischaracterized	Court improperly treated "interference" as merely time away from mother	Expanding grandparents’ time would reduce parents’/sibling time and intrude on parental discretion	Affirmed; trial court reasonably found expansion would interfere with parent‑child relationship

V.B. v. J.E.B., 55 A.3d 1193 (Pa. Super. 2012) (standard of review and scope in custody appeals)
Douglas v. Wright, 801 A.2d 586 (Pa. Super. 2002) (burden on grandparents to show custody/visitation is in child’s best interest and will not interfere with parent‑child relationship)
L.F.F. v. P.R.F., 828 A.2d 1148 (Pa. Super. 2003) (best‑interest factors govern custody determinations)
K.T. v. L.S., 118 A.3d 1136 (Pa. Super. 2015) (trial court must consider all §5328 factors when grandparents seek custody)
M.J.M. v. M.L.G., 63 A.3d 331 (Pa. Super. 2013) (no required level of detail—court must show factors were considered)
Ketterer v. Seifert, 902 A.2d 533 (Pa. Super. 2006) (child’s expressed preference is an important factor to weigh)
E.R. v. J.N.B., 129 A.3d 521 (Pa. Super. 2015) (appellate court will not reweigh credibility or evidence)