Jordan v. Jordan, 14 A.3d 1136

Elena L. Jordan and David A. Jordan divorced after 11 years; custody dispute over two daughters; trial court awarded joint legal and physical custody and appointed a parenting coordinator due to high conflict.
Ms. Jordan appeals the custody award and the appointment of a parenting coordinator.
Trial court found two intrafamily offenses by Mr. Jordan against Ms. Jordan, triggered a rebuttable presumption against joint custody, and then determined the presumption was rebutted.
Experts (notably Dr. Zuckerman) opined Mr. Jordan not dangerous and recommended joint custody with a parenting coordinator to implement a plan.
The August 21, 2009 custody order enumerated 17 best-interest factors, noted the intrafamily offenses, and provided day-to-day decision-making authority to the coordinator with the trial court retaining ultimate jurisdiction.
On December 29, 2009, the court appointed Roberta Eisen as parenting coordinator; Ms. Jordan challenged authority under Rule 53; the court upheld the appointment and related arrangements, including cost sharing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §16-914(a-1) explicit findings were required.	Jordan contends the court failed to cite §16-914(a-1).	Jordan argues lack of explicit findings requires reversal.	Implicit findings sufficed; no automatic reversal.
Whether the presumption against joint custody was properly rebutted.	Jordan argues alienation alone cannot rebut the presumption.	Jordan argues the court properly weighed evidence showing best interests.	Presumption rebutted by the court based on totality of circumstances.
Whether the court had authority to appoint a parenting coordinator over objection under Rule 53.	Jordan asserts lack of statutory authority and impropriety of appointment over objection.	Court properly used Rule 53 to create a temporary, limited deputy-structure for day-to-day decisions.	Rule 53-authorized appointment with appropriate limits.
Whether apportionment of parenting-coordinator costs was an abuse of discretion.	Jordan argues costs and potential offset against child support are improper.	Costs fairly allocated; offset against child support permissible.	Trial court did not abuse discretion; offset upheld.

Wilkins v. Ferguson, 928 A.2d 655 (D.C. 2007) (requires explicit consideration of intrafamily offenses and relevant best-interest factors)
P.F. v. N.C., 953 A.2d 1107 (D.C. 2008) (custody decisions must reflect safety and well-being considerations when intrafamily offenses exist)
In re J.T.B., 968 A.2d 106 (D.C. 2009) (parental-liberty interests balanced against child best interests in custody disputes)
Hutchins v. Compton, 917 A.2d 680 (D.C. 2007) (standard of review for child-custody determinations; abuse of discretion standard)
Lewis v. Lewis, 637 A.2d 70 (D.C. 1994) (limits on delegation of visitation decisions; custodial rights intact)