When a parent asks a court to change a custody schedule, the first procedural question is who will hear the case. In Pennsylvania, the answer depends on what kind of custody is at stake. A recent Superior Court decision makes that line clearer for parents on both sides of a dispute.

The Randazzo Decision

In Randazzo v. Passanita, a father petitioned for an equal, 50/50 custody arrangement. The mother had primary physical custody. Over her objection, the trial court sent the matter to a hearing officer rather than a judge.

The Superior Court found that this was an error. Because an equal split would take away the mother’s established primary custody, the request related to primary physical custody, even though the father never used those words. Pennsylvania’s rules allow hearing officers to decide partial custody matters, but primary physical custody must be decided by a judge.

The court also held that a judge cannot fix the problem by reading the hearing officer’s transcript. Custody decisions turn on credibility, and credibility is hard to judge from a cold record.

This ruling stands out in recent family law law news because it builds on a 2025 decision, McGee v. McDowell, which reached the same result even though both parents had agreed to the hearing officer.

Why the Labels Matter

Pennsylvania uses specific terms for physical custody, and each one carries weight:

• Primary physical custody means a parent has the child for the majority of the time.
• Partial physical custody means a parent has the child for less than the majority of the time.
• Shared physical custody means each parent has significant periods of time with the child.

A request that sounds modest can still shift a parent out of the primary role. Knowing the different types of child custody helps parents recognize what a petition actually asks for.

What Parents Should Take From This

If you have primary custody and the other parent files for more time, read the petition closely. Ask whether granting it would leave you with less than a majority of overnights. If it would, the case belongs before a judge. Raising that objection early, and in writing, protects the issue if the case is later appealed.

Courts today also expect detailed parenting plans, so the specifics of any proposed schedule deserve careful review. Evidence matters too. Messages and posts on social media are frequently introduced in contested custody hearings.

Related Financial Questions

Custody changes can affect both child support and tax obligations. Which parent may claim a child as a dependent is a frequent point of disagreement, and these questions often arise alongside dividing marital assets when parents are going through a divorce.

When to Get Advice

Custody procedure differs from state to state, and Pennsylvania’s rule on hearing officers may not apply where you live. Because these procedural rules vary, early guidance is especially valuable.

Many parents wait too long to speak with a divorce lawyer, but procedural errors are far easier to prevent than to correct on appeal. Seeking advice before a petition is filed or answered gives a parent the best opportunity to protect their position.

That advice often extends beyond the custody schedule itself. Custody is only one part of what a family attorney handles, but for most parents, it is the part that matters most.

Decisions like Randazzo are a reminder that custody outcomes can turn on procedure as much as on the facts. Following family law law news can help parents recognize when a change in the rules may affect their own case.

Whether you are responding to a request for more parenting time or considering a modification of your own, MSPM Law Resources offers information to help you prepare and can connect you with a family law attorney who handles custody matters in your area.