I have fielded several calls in recent months from family law practitioners looking to appeal a family law ruling on the basis that their client was denied their ability to present live testimony at a critical evidentiary hearing. The Supreme Court established what seemed to be a clear due process requirement for these types of hearings in 2007's Elkins v. Superior Court, and the Legislature expanded and codified that ruling in Family Code §217, which says that trial courts "shall" receive "live testimony" that is within the scope of an evidentiary hearing.