HomeMy WebLinkAbout2021-00244
AMANDA HARRIS IN THE COURT OF COMMON PLEAS OF
PATRICK HARRIS, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
v. CIVIL ACTION
JADEN ROSS NO. 2021-00244CIVIL TERM
DESIREE MORA,
Defendants
CUSTODY
IN RE: OPINION ON FATHER’S PRELIMINARY OBJECTIONS
HYAMS, J., JANUARY 26, 2022
Statement of Facts and Procedural History
Maternal Grandmother and her husband, Maternal Step-Grandfather (“Plaintiffs”), filed a
Complaint in Custody and an Emergency Petition for Special Relief onJanuary 19, 2021 with
regard to their daughter’s child, D.J.R.. At the time of the initial filings, the natural mother of the
subject minor child, Desiree Moran, (“Defendant/Mother”) was seventeen (17) years old. D.J.R..
was approximately eight (8) months old at the time this action was initiated. Father, Jaden Ross,
(Defendant/Father), was residing and continues to reside in Harrisburg with his Mother, the subject
minor child’s paternal grandmother.Plaintiffs were pro se at the time of their initial filings and
not all of the historical and background information within the pleadings was ultimately clear. On
January 20, 2021, the Plaintiffs’ Emergency Petition for Special Relief was granted on a limited
basis to permit time for theGuardian ad litem, (Katie Maxwell, Esquire was appointed within the
same Order), to perform an immediate investigation into the living arrangement for the subject
child, D.J.R..to include related custody actions, PFA’s, CYS involvement and any criminal
activity. In addition, the GAL was to properly identify the stakeholders/parents/guardians of
D.J.R..
Following receipt of the GAL’s report and recommendation, an Order was issued on
January 22, 2021, granting the Plaintiffs temporary physical and legal custody of D.J.R.. until an
expedited conciliation could be held. The Order further directed that both parents were to have
liberal visitation with the subject minor child at the home of Plaintiffs and the GAL’s appointment
would continued at least through the expedited conciliation. On March 26, 2021, Father filed an
Answer to Plaintiffs’ Emergency Petition for Special Relief and simultaneously filed Preliminary
Objections alleging that the Plaintiffs lacked standing, never were in loco parentis and that venue
was improper and should be transferred to Dauphin County. The first custody conciliation was
held on March 30, 2021 and the parties agreed to an Order (pending the resolution of Father’s
standing Preliminary Objections), which provided for shared legal custody between Plaintiffs,
Mother and Father. Primary physical custody was awarded to Maternal Grandmother with Father
having partial physical custody of D.J.R. every Friday at 4:30 p.m. to Monday at 7:30 a.m.
Mother’s periods of partial custody were to take place while D.J.R. was in maternal grandmother’s
physical custody, when agreed upon by Mother and Maternal Grandmother.
On June 3, 2021, Father filed an Emergency Petition for Special Relief seeking removal of
the D.J.R. from the Plaintiffs’ care and providing the Defendants emergency shared custody. A
June 3, 2021 Order of Court denied Father’s requested emergency relief for failing to identify a
viable emergency. The parties were further directed to work together to identify a reasonable
custody schedule that permits D.J.R. safe contact with, and parenting by, her very young parents.
Not to be outdone by Father, on July 15, 2021, Maternal Grandmother filed her own Emergency
Petition for Special Relief also alleging problems with the custodial schedule exchanges and other
non-emergency allegations. On July 16, 2021 Maternal Grandmother’s Emergency Petition was
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denied for failing to identify any type or form of an emergency. The parties were directed to return
to conciliation to address custodial exchanges including the location of those exchanges and
directed the parties not to engage in video taping or recording the exchanges. The parties attended
conciliation on August 3, 2021 and agreed to an Order that modified the custodial exchange
location for Monday mornings.
By Order of Court, the Father’s preliminary objections were scheduled for an evidentiary
hearing and argument to be held on October 25, 2021. The pertinent factual background presented
at the hearing can be summarized as follows:
Mother attended the hearing, but was unrepresented. She wants to share physical and legal
custody with the Father only. Father has resided in Dauphin County since July 2020 where he
lives with his mother. Prior to that, he briefly resided with the Plaintiffs in Cumberland County
from April 2020-July 2020. Both he and Mother were residing there just before and after D.J.R.’s
birth. Father and Mother provided care to D.J.R. from the April 2020-July 2020 timeframe. Father
and Mother purchased baby items for the child, fed the child and took care ofthe child if not
working. Father and Mother took the child to the pediatrician during the first few months of her
life, although she was behind on vaccinations at the end of 2020 as the parents did not have
insurance for her. Father has not taken the child to the doctor in 2021 because Maternal
Grandmother and Mother take the child to the doctor.
Mother and Father left the Plaintiffs’ residence towards the end of July 2020 as a result of
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tension in the home after Plaintiffs learned that Mother was pregnant again.In July 2020, Mother
moved in with her biological father,who lived in Dauphin County, and Father moved in with his
mother, who also lived in Dauphin County. Mother and Father followed a fifty/fifty custody
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Mother subsequently terminated this pregnancy.
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schedule of D.J.R. when Mother wasliving with maternal grandfather (her biological father) and
Father was living with paternal grandmother. During the timeframe that Mother and D.J.R. were
residing with biological paternal grandfather (July 2020 – December 2020), Mother was providing
the care to D.J.R. while residing in his home, with assistance from the grandparents. Maternal
Grandmother continued to see D.J.R. during this time as occasionally Mother would occasionally
visit.
In January 2021, Father and Mother got into an argument, presumably over the phone or
text messages. Plaintiff/Maternal Grandmother, drove Mother to Father’s residence. Maternal
Grandmother remained in a vehicle while the Mother and Father proceeded to get into a verbal
and physical altercation. Father requested assistance from Maternal Grandmother, but she
remained in the vehicle. The police were called, and Mother was the only one charged as she had
thrown rocks through the residence of paternal grandmother’s window. Paternal grandmother filed
for and obtained a PFA against Mother as a result of this incident. D.J.R. was not at the Father’s
home and was not with Mother and Maternal Grandmother during this January 2021 altercation.
It was this incident that resulted in Plaintiffs filing a Complaint in custody as well as an Emergency
Custody Petition initiating the instant litigation.
Father has been working at Sheetz since April/May 2021. Father acknowledged that he
uses marijuana two to three times a week and he does not have a medical marijuana card. He
typically does not use marijuana during his custodial period, but if he does, he leaves the child in
the care of his mother and walks somewhere outside to use marijuana. Mother and Father have
moved past the January 2021 altercation and are committed to co-parenting. Mother believes she
is able to physically care for the child and she would like to have physical custody, which would
be shared fifty/fifty with the Father. Mother has primarily lived with her biological father over the
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last several years, but is currently residing with Plaintiffs because Plaintiffs currently haveprimary
physical custody of D.J.R. Mother would not necessarily move out of Plaintiffs’ home if Mother
would be awarded aspects of physical custody of D.J.R., but it would depend on whether this
change in custody would cause tension within the household. Mother had mental health concerns
and treatment while she was a minor. She is not currently engaged in mental health treatment, and
she has taken herself off her medications. She is currently working as a manager at Hot Topic, a
store located at that Capitol City Mall.
Discussion
Generally, the Child Custody Act does not permit third parties to seek custody of a child
contrary to the wishes of that child'sparents. The Act provides several exceptions to this rule,
which apply primarily to grandparents and great-grandparents.” K.W. v. S.L., 157 A.3d 498, 504
(Pa. Super. 2017).The most recent version of theGrandparent Custody and Visitation Act
provides two separate provisions forgrandparentsseeking custody of their grandchildren. Any
grandparentmay seek any form of custody pursuant to23 Pa.C.S. § 5324. In addition, for
grandparentsin certain situations, they may seek partial custody pursuant to section 5325. Here,
there is no dispute that only section 5324 could apply, andPlaintiffs claim they meet section
5324(2) and/or section 5324(3)(iii)(B). That section provides the following in relevant part:
§ 5324. Standing for any form of physical custody or legal custody
The following individuals may file an action under this chapter for any form of physical
custody or legal custody:
(1) A parent of the child.
(2) A person who stands in loco parentis to the child.
(3) A grandparent of the child who is not in loco parentis to the child:
(i) whose relationship with the child began either with the consent of a parentof
the child or under a court order;
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(ii) who assumes or is willing to assume responsibility for the child; and
(iii) when one of the following conditions is met:
(A) the child has been determined to be a dependent child under 42 Pa.C.S. Ch. 63
(relating to juvenile matters);
(B) the child is substantially at risk due to parental abuse, neglect, drug or alcohol abuse
or incapacity; or
(C) the child has, for a period of at least 12 consecutive months, resided with the
grandparent, excluding brief temporary absences of the child from the home, and is
removed from the home by the parents, in which case the action must be filed within six
months after the removal of the child from the home.
23 Pa.C.S. § 5324.
It is evident from the testimony and evidence presented that these two young parents will
need guidance, assistance and support along their parental journey. However, this is not unlike
the majority of new parents. As the old adage goes, “it takes a village to raise a child.” D.J.R.’s
village includes various grandparents and a great-grandparent. The outcome of the pending
preliminary objections should not change the fact that Mother and Father will need guidance and
support as new parents and that they have supportive resources through their parents, step-parent
and great-grandparent.It is in the best interests of D.J.R. for her parents to receive this support
from their family members. Notwithstanding this court’s desire to place the child best interests
first and foremost, third party standing isn’t premised on a best interest standard. The concept of
standingis vital in ensuring that cases are presented to the court by an individual who has a
genuine,and not merely a theoretical,interestin the matter. Thus, the traditional test forstanding
is that the proponent of the action must have a direct, substantial and immediateinterestin the
matter at hand.D.G. v. D.B.,91 A.3d 706 (Pa. Super. 2014). In M.W. v. S.T.,196 A.3d 1065 (Pa.
Super. 2018), the Pennsylvania SuperiorCourt emphasized:
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In the area of child custody, principles of standinghave been applied with particular
scrupulousness because they serve a dual purpose: not only to protect theinterestof the
court system by assuring that actions are litigated by appropriate parties, but also to
prevent intrusion into the protected domain of the family by those who are merely
strangers, however well-meaning.
Id. at 1069 (citation omitted).
Standing isa conceptually distinct legal question which has no bearing on the central
issue within the custody action-who is entitled to physical and legal custody of a child in light of
his or her best interests. C.G. v. J.H., 193 A.3d 891, 898 (Pa. 2018).
Plaintiffs have not met their burden of establishing that they stood in loco parentis to D.J.R.
While Maternal Grandmother has occasionally provided shelter, transportation to and from
medical appointments, and general care to the child, at the time the Complaint was filed, D.J.R.
had spent the majority of her life residing with one of her parents in homes of her maternal
(biological) grandfather or paternal grandmother. Maternal Grandmother’s conduct from April
2020 – January 2021 is commendable and surely out of love for her daughter and granddaughter,
but she was simply assisting her daughter who was in need of the support of her parents as she
began her motherhood journey. Maternal Grandmother’s conduct did not demonstrate that she
had assumed all rights and responsibilities of parenthoodover D.J.R. See D.G. v. D.B., 91 A.3d
706, 711–12 (Pa. Super. 2014).
In addition, Plaintiffs have also failed to demonstrate standing under 5324(3) as they did
not prove that D.J.R. is substantially at risk due to parental abuse, neglect, drug or alcohol abuse
or incapacity. 23 Pa.C.S. § 5324(3)(iii)(B). In fact, there was little risk shown as it relates
specifically to D.J.R., let alone “substantial” risk. While there was evidence that Father utilizes
marijuana without a proper prescription, there was no credible evidence that he does so while he
is in the primary caretaking role of the child. The January 2021 incident that led to an altercation
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between the parents and a PFA being filed and granted against the Mother occurred at a time that
the child was not present. The parents are now a year older since that domestic incident and
appeared sincere that they are committed to working together to co-parent their child. There is no
current involvement with any child welfare agencies and any referrals made were investigated and
unfounded. The parents have ensured that D.J.R. has appropriate housing, clothing and her
physical needs are being met. The maternal (biological) grandfather and paternal grandmother
both testified that they would continue to support the Mother and Father and assist the parents to
properly care for D.J.R. as her primary caretakers. Therefore, it has not been shown that D.J.R. is
substantially at risk due to ongoing parental behaviors.
Following careful analysis of 23 Pa.C.S. § 5324, and the record in its entirety, Plaintiffs have
failed to meet their burden on proving standing and the following Order is entered:
ORDER
th
And now, this 26day of January, 2022, following an evidentiary hearing and argument
on October 25, 2021, Defendant, Jaden Ross’s Preliminary Objection to Standing is GRANTED
and the Complaintis Dismissed. The Preliminary Objection to Improper Venue is MOOT as the
action in Cumberland County is null and void.
BY THE COURT:
Carrie E. Hyams, J.
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Distribution:
Jeanné Costopoulos, Esq.
Po Box 22018
Sarasota, Fl 34276
jbclegal@gmail.com
Desiree Mora
3315 Trinity Rd.
Harrisburg, PA 17109
desireemmora@yahoo.com
Kelli Statt, Esq.
4800 Linglestown Rd.
Suite 104
Harrisburg, PA 17112 United States
kstatt@jasoncarpenterlaw.com
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