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FATHER PAID CHILD SUPPORT PRIOR TO SENTENCING FOR WILLFUL FAILURE TO PAY, FAMILY COURT SHOULD NOT HAVE ISSUED THE ORDER OF COMMITMENT.

The Third Department determined a sentence of incarceration for father’s willful failure to pay child support was proper. However, because the support was paid by father prior to sentencing, Family Court abused its discretion by issuing the order of commitment:

Upon a willful violation, Family Court is authorized to impose a sentence of incarceration of up to six months … . Such a sentence is in the nature of a civil contempt, which “may only continue until such time as the offender, if it is within his or her power, complies with the support order” … . Since respondent cured the default prior to sentencing, we conclude that Family Court abused its discretion by issuing the order of commitment. Matter of Provost v Provost, 2017 NY Slip Op 01422, 3rd Dept 2-23-17

FAMILY LAW (FATHER PAID CHILD SUPPORT PRIOR TO SENTENCING FOR WILLFUL FAILURE TO PAY, FAMILY COURT SHOULD NOT HAVE ISSUED THE ORDER OF COMMITMENT)/CHILD SUPPORT (FATHER PAID CHILD SUPPORT PRIOR TO SENTENCING FOR WILLFUL FAILURE TO PAY, FAMILY COURT SHOULD NOT HAVE ISSUED THE ORDER OF COMMITMENT)

UPON REVERSAL OF MOTHER’S MURDER AND MANSLAUGHTER CONVICTIONS, MOTHER ENTITLED TO NEW DISPOSITIONAL HEARING ON TERMINATION OF HER PARENTAL RIGHTS.

The Third Department determined respondent mother was entitled to a new dispositional hearing on termination of her parental rights. At the time of the prior hearing she was facing a long incarceration for murder and manslaughter. However, those convictions were subsequently reversed:

Remittal is … required for a new dispositional hearing. Upon appeal from respondent’s criminal conviction, this Court modified the judgment of conviction by reversing her murder and manslaughter convictions and dismissing the underlying counts of the indictment. Respondent is accordingly not facing the lengthy term of imprisonment anticipated at the time the dispositional order was issued and, as such, it is unclear whether the best interests of the children continue to demand the termination of her parental rights. Thus, we agree with petitioner and respondent that a new dispositional hearing is required … . Matter of Zoey O. (Veronica O.), 2017 NY Slip Op 01413, 3rd Dept 2-23-17

FAMILY LAW (UPON REVERSAL OF MOTHER’S MURDER AND MANSLAUGHTER CONVICTIONS, MOTHER ENTITLED TO NEW DISPOSITIONAL HEARING ON TERMINATION OF HER PARENTAL RIGHTS)/PARENTAL RIGHTS (UPON REVERSAL OF MOTHER’S MURDER AND MANSLAUGHTER CONVICTIONS, MOTHER ENTITLED TO NEW DISPOSITIONAL HEARING ON TERMINATION OF HER PARENTAL RIGHTS)

WIFE ENTITLED TO A PERCENTAGE OF HUSBAND’S ENHANCED EARNING CAPACITY BY ENABLING HUSBAND’S LONG WORKING HOURS AND HIS STUDY FOR MEDICAL BOARD EXAMS.

The First Department determined defendant wife was properly awarded a percentage of plaintiff husband’s enhanced earning capacity related to his medical license. Husband worked long hours and unpopular shifts as an anesthesiologist to earn double the average salary of his peers—over $800,000 per year at one point. Wife enabled husband’s intense work schedule by caring for the children and home. [The decision is extensive and covers many issues not summarized here]:

The party seeking distribution of an award based on the other party’s enhanced earning capacity must establish its value through expert testimony … . Defendant’s expert used a methodology that is commonly used when calculating the value of enhanced earning capacity … . Plaintiff’s disagreement with certain assumptions made by the expert was not a basis to simply disregard the expert’s opinion and treat it as a complete nullity. Some of plaintiff’s criticisms resulted in adjustments in value at trial. * * *

The court … properly exercised its discretion in making a distributive award equal to 10% of plaintiff’s enhanced earnings … . It is well-established law that both parties in a matrimonial action are entitled to “fundamental fairness in the allocation of marital assets, and that the economic and noneconomic contributions of each spouse are to be taken into account” …. . In reaching its decision the court below considered the statutory factors listed in Domestic Relations Law § 236, as well as the nontitled defendant spouse’s direct and/or indirect contributions to the marriage … .

… [P]laintiff was earning almost twice as much as other … doctors [in the firm] because he worked extraordinarily long hours, accepted unpopular shifts, like holidays, weekends and evenings, and was better compensated precisely because plaintiff kept this “totally unbalanced life.” By not adhering to a more balanced work schedule, plaintiff necessarily shifted primary responsibility for his home life to defendant. Although he may have borne equal, if not primary, responsibility for the children when he was home, this was often a physical impossibility, given his demanding work schedule. Defendant not only made it possible for plaintiff to work the grueling schedule that he kept, she also made sure plaintiff was able to study without interruption for the boards on two separate occasions. She did this by taking the children away to visit relatives and doing other things to keep them out of his way. Ning-Yen Yao v Karen Kao-Yao, 2017 NY Slip Op 01440, 1st Dept 2-23-17

 

FAMILY LAW (WIFE ENTITLED TO A PERCENTAGE OF HUSBAND’S ENHANCED EARNING CAPACITY BY ENABLING HUSBAND’S LONG WORKING HOURS AND HIS STUDY FOR MEDICAL BOARD EXAMS)/EQUITABLE DISTRIBUTION (WIFE ENTITLED TO A PERCENTAGE OF HUSBAND’S ENHANCED EARNING CAPACITY BY ENABLING HUSBAND’S LONG WORKING HOURS AND HIS STUDY FOR MEDICAL BOARD EXAMS)/ENHANCED EARNING CAPACITY (FAMILY LAW, EQUITABLE DISTRIBUTION, WIFE ENTITLED TO A PERCENTAGE OF HUSBAND’S ENHANCED EARNING CAPACITY BY ENABLING HUSBAND’S LONG WORKING HOURS AND HIS STUDY FOR MEDICAL BOARD EXAMS)

ABSENT PROOF OF 16-YEAR-OLD CHILD’S COLLEGE PLANS, ANY AWARD OF COLLEGE EXPENSES WOULD BE PREMATURE.

The Second Department, in a decision covering many equitable distribution issues not summarized here, determined any award of college expenses for a 16-year-old child was premature. No evidence was presented concerning the child’s academic wishes or plans:

… [T]he court did not err in declining to direct the defendant to contribute his pro rata share of the parties’ unemancipated child’s future college expenses. “The court may direct a parent to contribute to a child’s college education pursuant to Domestic Relations Law § 240(1-b)(c)(7)” … . “However, when college is several years away, and no evidence is presented as to the child’s academic interests, ability, possible choice of college, or what his or her expenses might be, a directive compelling [a parent] to pay for those expenses is premature and not supported by the evidence” … . At the time of the trial, the parties’ unemancipated child was 16 years old and was entering his junior year of high school. There was no evidence presented as to his academic interests, his possible choice of college, or what the expenses of college might be. Accordingly, the plaintiff’s request that the court direct the defendant to contribute his pro rata share of the parties’ unemancipated child’s future college expenses was premature … . Repetti v Repetti, 2017 NY Slip Op 01396, 2nd Dept 2-22-17

FAMILY LAW (EQUITABLE DISTRIBUTION, ABSENT PROOF OF 16-YEAR-OLD CHILD’S COLLEGE PLANS, ANY AWARD OF COLLEGE EXPENSES WOULD BE PREMATURE)/EQUITABLE DISTRIBUTION (COLLEGE EXPENSES, (EQUITABLE DISTRIBUTION, ABSENT PROOF OF 16-YEAR-OLD CHILD’S COLLEGE PLANS, ANY AWARD OF COLLEGE EXPENSES WOULD BE PREMATURE)/COLLEGE EXPENSES (FAMILY LAW, EQUITABLE DISTRIBUTION, ABSENT PROOF OF 16-YEAR-OLD CHILD’S COLLEGE PLANS, ANY AWARD OF COLLEGE EXPENSES WOULD BE PREMATURE)

FAMILY COURT SHOULD NOT HAVE SUMMARILY DENIED COUNTY’S APPLICATION FOR PATERNITY DNA TESTING WITHOUT REQUIRING PUTATIVE FATHER TO RAISE A QUESTION OF FACT TO SUPPORT THE EQUITABLE ESTOPPEL DEFENSE; COUNTY HAS STATUTORY AUTHORITY TO BRING A PATERNITY ACTION WHEN THE MOTHER OR CHILD IS LIKELY TO BECOME A PUBLIC CHARGE.

The Second Department, reversing Family Court, determined Family Court should not have denied, without a hearing, the County’s request for DNA paternity testing. The putative father had not raised a question of fact to support his assertion of the equitable estoppel defense (demonstrating that another had developed a father-child relationship). Only after determining whether equitable estoppel defense applies can the propriety of DNA testing be considered. The County has the statutory authority to bring a paternity proceeding when the mother or child is likely to become a public charge:

… [A]rticle 5 of the Family Court Act still retains as an objective the protection of the public from bearing the cost of supporting . . . children where there exists a viable, legally obligated source of support” … . Accordingly, “section 522 of the Family Court Act provides that, among other persons, a public welfare official of the county, city or town where the mother resides, or the child is found, may originate such proceedings, if the mother or child is or is likely to become a public charge'” … . * * *

… [T]he doctrine of equitable estoppel may be used by a purported biological father to prevent an adverse party from asserting that he is the biological father where the child has developed a close relationship with another father figure such that it would be detrimental to the child’s interests to disrupt that relationship … . Under such circumstances, in order to be entitled to a hearing on the issue of whether equitable estoppel should be applied, a putative father must raise an issue of fact as to whether “a determination that he is in fact the father would disturb any relationship the child[ ] may have had with any other father figure” … . “[W]hether it is being used in the offensive posture to enforce rights or the defensive posture to prevent rights from being enforced, equitable estoppel is only to be used to protect the best interests of the child” … . …

The Family Court … erred to the extent that it based its order dismissing the petition on its prior determination, in effect, denying the County’s application for DNA testing. The Family Court should not have summarily denied the County’s application without first requiring the putative father to raise an issue of fact with respect to his defense of equitable estoppel … . Matter of Suffolk County Dept. of Social Servs. v James D., 2017 NY Slip Op 01369, 2nd Dept 2-22-17

 

FAMILY LAW (PATERNITY, FAMILY COURT SHOULD NOT HAVE SUMMARILY DENIED COUNTY’S APPLICATION FOR PATERNITY DNA TESTING WITHOUT REQUIRING PUTATIVE FATHER TO RAISE A QUESTION OF FACT TO SUPPORT THE EQUITABLE ESTOPPEL DEFENSE)/PATERNITY (FAMILY COURT SHOULD NOT HAVE SUMMARILY DENIED COUNTY’S APPLICATION FOR PATERNITY DNA TESTING WITHOUT REQUIRING PUTATIVE FATHER TO RAISE A QUESTION OF FACT TO SUPPORT THE EQUITABLE ESTOPPEL DEFENSE)/DNA TESTING (FAMILY LAW, PATERNITY, FAMILY COURT SHOULD NOT HAVE SUMMARILY DENIED COUNTY’S APPLICATION FOR PATERNITY DNA TESTING WITHOUT REQUIRING PUTATIVE FATHER TO RAISE A QUESTION OF FACT TO SUPPORT THE EQUITABLE ESTOPPEL DEFENSE)/FAMILY LAW (PATERNITY, COUNTY HAS THE STATUTORY AUTHORITY TO BRING A PATERNITY ACTION WHEN THE MOTHER OR CHILD IS LIKELYT TO BECOME A PUBLIC CHARGE)/PATERNITY (COUNTY HAS THE STATUTORY AUTHORITY TO BRING A PATERNITY ACTION WHEN THE MOTHER OR CHILD IS LIKELYT TO BECOME A PUBLIC CHARGE)/PUBLIC CHARGE (FAMILY LAW, PATERNITY, COUNTY HAS THE STATUTORY AUTHORITY TO BRING A PATERNITY ACTION WHEN THE MOTHER OR CHILD IS LIKELYT TO BECOME A PUBLIC CHARGE)

SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED.

The Second Department determined a waiver of maintenance, equitable distribution and an award of attorney’s fees included in the prenuptial agreement did not preclude Supreme Court from awarding temporary relief prior to termination of the marriage. The Second Department also held that Supreme Court’s pendente lite child support deviated from the criteria of the Child Support Standards Act (CSSA) and therefore an explanation for the deviation was required:

Although the prenuptial agreement contains a waiver of maintenance, equitable distribution, and an award of attorney’s fees in the event of termination of the marriage, it does not bar temporary relief, including pendente lite maintenance and attorney’s fees during the pendency of this litigation … . While the Supreme Court properly awarded the plaintiff interim attorney’s fees, the court, without explanation, improvidently denied that branch of the plaintiff’s motion which was for an award of pendente lite maintenance. Accordingly, we remit the matter to the Supreme Court, Nassau County, for a new determination of that branch of the plaintiff’s motion … .

In determining an award of pendente lite child support, courts may, in their discretion, apply the Child Support Standards Act (hereinafter CSSA) standards and guidelines, but they are not required to do so … . “However, under some circumstances, particularly where sufficient economic data is available, an award of temporary child support that deviates from the level that would result if the provisions of the CSSA were applied may constitute an improvident exercise of discretion, absent the existence of an adequate reason for the deviation” … . Here, the court failed to provide any explanation as to how it determined the amount of the award of pendente lite child support. Under the circumstances of this case, the matter must be remitted to the Supreme Court … . Kashman v Kashman, 2017 NY Slip Op 01343, 2nd Dept 2-22-17

 

FAMILY LAW (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)/PRENUPTIAL AGREEMENT (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)/PENDENTE LITE MAINTENANCE (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)/PENDENTE LITE CHILD SUPPORT (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)/MAINTENANCE (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)CHILD SUPPORT (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)/CHILD SUPPORT STANDARDS ACT (CSSA) (SUPREME COURT SHOULD HAVE ORDERED PENDENTE LITE MAINTENANCE DESPITE WAIVER OF MAINTENANCE UPON TERMINATION OF THE MARRIAGE IN THE PRENUPTIAL AGREEMENT, SUPREME COURT FAILED TO EXPLAIN THE DEVIATION FROM THE CHILD SUPPORT STANDARDS ACT IN ITS AWARD OF PENDENTE LITE CHILD SUPPORT, CASE REMITTED)

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FAMILY COURT SHOULD HAVE MADE FINDINGS TO ALLOW JUVENILE TO PETITION FOR SPECIAL IMMIGRANT JUVENILE STATUS.

The Second Department determined Family Court should have granted the motion for findings to allow a juvenile to petition for special immigrant juvenile state (SIJS):

Based upon our independent factual review, we find that the record fully supports the petitioner’s contention that, because the child’s mother neglected him, reunification with the mother is not a viable option … . Contrary to the Family Court’s determination, the record demonstrated that the physical, mental, or emotional condition of the child had been impaired or was in imminent danger of becoming impaired as a result of the failure of the mother to exercise a minimum degree of care “in supplying the child with adequate food, clothing, shelter or education . . . though financially able to do so or offered financial or other reasonable means to do so” … . Indeed, the petitioner’s testimony at the hearing demonstrated that although the mother received financial assistance to provide for the child’s clothing and education, the mother failed to use such assistance for the child’s benefit. The child’s testimony corroborated the petitioner’s testimony in this respect.

Accordingly, the Family Court should have granted the petitioner’s motion for the issuance of an order making the requisite declaration and specific findings so as to enable the child to petition for SIJS. Matter of Wilson A.T.Z. (Jose M.T.G.–Manuela Z.M.), 2017 NY Slip Op 01215, 2nd Dept 2-15-17

 

FAMILY LAW (SPECIAL IMMIGRANT JUVENILE STATUS, FAMILY COURT SHOULD HAVE MADE FINDINGS TO ALLOW JUVENILE TO PETITION FOR SPECIAL IMMIGRANT JUVENILE STATUS)/IMMIGRATION LAW (SPECIAL IMMIGRANT JUVENILE STATUS, FAMILY COURT SHOULD HAVE MADE FINDINGS TO ALLOW JUVENILE TO PETITION FOR SPECIAL IMMIGRANT JUVENILE STATUS)/SPECIAL IMMIGRANT JUVENILE STATUS (SIJS) ( FAMILY COURT SHOULD HAVE MADE FINDINGS TO ALLOW JUVENILE TO PETITION FOR SPECIAL IMMIGRANT JUVENILE STATUS)

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CHILD SHOULD NOT HAVE BEEN REMOVED FROM FATHER’S CARE, EVEN THOUGH CHILD HAS BEEN RETURNED, APPEAL NOT MOOT BECAUSE OF THE STIGMA OF REMOVAL.

The Second Department, reversing Family Court, determined the removal application should not have been granted and father’s appeal of the removal was not moot, even though the child had been returned to the father:

Although it is undisputed that the child has been returned to the father’s care, the father’s appeals are not academic. The child’s removal created a permanent and significant stigma … .

“In determining a removal application pursuant to Family Court Act § 1027, the court must engage in a balancing test of the imminent risk with the best interests of the child and, where appropriate, the reasonable efforts made to avoid removal or continuing removal'” … . Here, the petitioner failed to establish that the child would be subjected to imminent risk if she were not placed in the custody of the petitioner pending the outcome of the neglect proceeding. Under the circumstances of this case, concerns about, inter alia, the adequacy of the father’s plan to care for the child did not amount to an imminent risk to the child’s life or health that could not be mitigated by reasonable efforts to avoid removal. Matter of Emmanuela B. (Jean E.B.), 2017 NY Slip Op 01195, 2nd Dept 2-15-17

 

FAMILY LAW (NEGLECT, REMOVAL, CHILD SHOULD NOT HAVE BEEN REMOVED FROM FATHER’S CARE, EVEN THOUGH CHILD HAS BEEN RETURNED, APPEAL NOT MOOT BECAUSE OF THE STIGMA OF REMOVAL)/APPEALS (FAMILY LAW, CHILD SHOULD NOT HAVE BEEN REMOVED FROM FATHER’S CARE, EVEN THOUGH CHILD HAS BEEN RETURNED, APPEAL NOT MOOT BECAUSE OF THE STIGMA OF REMOVAL)/NEGLECT (CHILD SHOULD NOT HAVE BEEN REMOVED FROM FATHER’S CARE, EVEN THOUGH CHILD HAS BEEN RETURNED, APPEAL NOT MOOT BECAUSE OF THE STIGMA OF REMOVAL)/REMOVAL (CHILD NEGLECT, FAMILY LAW, CHILD SHOULD NOT HAVE BEEN REMOVED FROM FATHER’S CARE, EVEN THOUGH CHILD HAS BEEN RETURNED, APPEAL NOT MOOT BECAUSE OF THE STIGMA OF REMOVAL)

FAMILY COURT COULD NOT ALLOW VISITATION WHILE A CRIMINAL ORDER OF PROTECTION IS IN PLACE.

The Second Department determined that Family Court properly denied mother’s motion for kinship visitation because a criminal court order of protection was in place:

As a general rule, the “Family Court does not have jurisdiction to countermand the provisions of a criminal court order of protection” … . Thus, where a criminal court order of protection bars contact between a parent and child, the parent may not obtain visitation until the order of protection is vacated or modified by the criminal court … . However, the criminal court has authority to determine whether its order of protection is “subject to” subsequent Family Court orders, and where the criminal court order of protection “expressly contemplates future amendment of its terms by a subsequent Family Court order pertaining to custody and visitation,” the Family Court is not precluded from granting custody or visitation by the terms of the order of protection … . Here, since the Supreme Court’s temporary order of protection dated April 1, 2016, did not state that it was “subject to” subsequent Family Court orders, the Family Court had no basis to permit “kinship visitation” supervised by the maternal grandmother. Matter of Rihana J.H. (Quianna J.), 2017 NY Slip Op 01202, 2nd Dept 2-15-17

FAMILY LAW (FAMILY COURT COULD NOT ALLOW VISITATION WHILE A CRIMINAL ORDER OF PROTECTION IS IN PLACE)/VISITATION (FAMILY LAW, FAMILY COURT COULD NOT ALLOW VISITATION WHILE A CRIMINAL ORDER OF PROTECTION IS IN PLACE)/CRIMINAL LAW (FAMILY LAW, ORDER OF PROTECTION, FAMILY COURT COULD NOT ALLOW VISITATION WHILE A CRIMINAL ORDER OF PROTECTION IS IN PLACE)/ORDER OF PROTECTION (FAMILY LAW,  FAMILY COURT COULD NOT ALLOW VISITATION WHILE A CRIMINAL ORDER OF PROTECTION IS IN PLACE)

FATHER SHOULD NOT HAVE BEEN AWARDED SOLE CUSTODY IN THE ABSENCE OF A HEARING.

The Second Department, reversing Supreme Court, determined father should not have been awarded sole custody without a hearing:

The Supreme Court erred in awarding the father sole custody of the child in the absence of a hearing to determine the best interests of the child. “[A] court opting to forgo a plenary hearing must take care to clearly articulate which factors were—or were not—material to its determination, and the evidence supporting its decision” … . The court failed to do so here. Furthermore, the issue of custody was not discussed at the … court appearances that resulted in the issuance of the final order of custody and visitation. Under these circumstances, the mother’s motion to vacate the final order of custody and visitation … , should have been granted. Matter of Fraser v Fleary, 2017 NY Slip Op 01197, 2nd Dept 2-15-17

FAMILY LAW (FATHER SHOULD NOT HAVE BEEN AWARDED SOLE CUSTODY IN THE ABSENCE OF A HEARING)/CUSTODY (FAMILY LAW, FATHER SHOULD NOT HAVE BEEN AWARDED SOLE CUSTODY IN THE ABSENCE OF A HEARING)

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