The evolution of the courts' application of the new child custody statute continues at a consistent pace. A recurring issue that has been addressed by the Pennsylvania Superior Court pertains to the requirement of the trial court to provide the reasons for its decisions in custody cases on the record in open court or in a written opinion or order.

Recently, the Superior Court addressed the timing of when the trial court is required to delineate the reasons for custody decisions. In the case of C.B. v. J.B., 2013 Pa. Super. 92 (April 22, 2013), the Superior Court held that the trial court must specify its reasoning for its custody decisions at or near the time of the ruling and not wait until it issues a 1925(a) opinion in the event of an appeal.

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