Child Custody • Relocation • Section 5337 • Prior Approval • Sanction
J.M v. K. W., PICS Case No. 17-0958 (Pa. Super. May 31, 2017) Bowes, J. (22 pages).
Trial court properly found mother in contempt for relocating with the children in contravention of an order directing compliance with §5337 but trial court erred in finding her in contempt for enrolling child in preschool because there had been no legal determination of custody and abused its discretion in changing custody as a contempt sanction because there was no express notice that custody would be at issue. Affirmed in part and reversed in part.
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