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Henderson, J. v. Kardosh, J.

2026-09-01

Summary

Holding. The trial court violated the maternal grandparents' due process rights by implicitly granting the mother's relocation request without providing adequate notice that relocation would be reconsidered at the review hearing. The court vacated the July 3, 2025 custody order and remanded the case for imposition of the February 28, 2025 interim order as the final order.

This custody dispute involves two minor children whose father, Joseph Henderson, sought custody in 2020, alleging substance abuse and mental instability by their mother, Julia Kardosh. The maternal grandparents intervened and eventually obtained sole legal and primary physical custody in October 2023. After a six-day custody trial in early 2025, the trial court issued an interim order on February 28, 2025, maintaining the grandparents' custody while denying the mother's request to relocate the children to New Jersey.

On June 23, 2025, a review hearing was held to assess the parties' compliance with the interim order. However, the court did not notify the maternal grandparents that it would reconsider the mother's previously denied relocation request. At the conclusion of the review hearing, the court issued a final order on July 3, 2025, that transferred primary physical custody to the mother and implicitly granted her request to relocate to New Jersey. The maternal grandparents appealed, arguing this modification violated their due process rights because they received no notice that relocation would be reconsidered.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether the trial court violated due process by changing custody and granting relocation without notice
  • Procedural due process requirements for relocation proceedings under Pennsylvania law
  • Adequacy of notice regarding issues to be addressed at a custody review hearing

Procedural posture

The maternal grandparents appealed from the trial court's final custody order entered July 3, 2025, which modified their previously granted sole custody and implicitly approved the mother's relocation to New Jersey.

Authorities cited

Opinion

majority opinion

J-A10006-26 2026 PA Super 192

JOSEPH HENDERSON : IN THE SUPERIOR COURT OF

: PENNSYLVANIA

:

v. :

:

:

JULIA KARDOSH :

:

: No. 2065 EDA 2025

v. :

:

:

MARY ELLEN KARDOSH AND WILLIAM :

KARDOSH :

:

Appellants :

Appeal from the Order Entered July 3, 2025

In the Court of Common Pleas of Chester County

Civil Division at No: 2020-05201-CU

BEFORE: STABILE, J., LANE, J., and STEVENS, P.J.E.*

OPINION BY STABILE, J.: FILED SEPTEMBER 1, 2026

Appellants, Mary Ellen and William Kardosh (“Maternal Grandparents”),

appeal from the final custody order entered on July 3, 2025, by the Court of

Common Pleas of Chester County.1 Upon review, we vacate the July 3, 2025,

order and remand for imposition of the February 28, 2025, order as a final

order.

This case has a very lengthy and litigious history. On August 10, 2020,

Joseph Henderson (Father) filed a petition for emergency relief and complaint

* Former Justice specially assigned to the Superior Court.

1 This is one of four appeals taken from the July 3, 2025, order.

See 1874

EDA 2024 (Father’s appeal), 2012 and 2013 EDA 2025 (Mother’s appeals). J-A10006-26

for custody, wherein he sought custody of the parties two minor children, S.H.

(DOB: 6/2016) and V.H. (DOB: 11/2018), due to the alleged substance abuse

and mental instability of Julia Kardosh (Mother). Mother responded and

averred that she left Father and moved to Maternal Grandparents’ home to

protect herself and the children from ongoing harm. Following a hearing on

September 11, 2020, the trial court entered a temporary custody order

awarding the parties shared legal custody. See Order, 9/14/20.2 Mother was

awarded primary physical custody and Father partial physical custody. Id.

However, Father was not permitted to exercise his custodial periods at his

residence until he completed a home assessment. 3 Id. Additionally, due to

allegations of substance abuse and mental instability, the court ordered both

parents to undergo a psychological screening by Bruce E. Mapes, Ph.D. to

assess their mental fitness to safely parent the children. 4 Id.

On October 20, 2020, Maternal Grandparents filed a petition to

intervene, citing 23 Pa.C.S.A. §§ 5324 (standing for any form of custody) and

5325 (standing for partial or supervised custody). Father objected and Mother

consented to the intervention. Following a hearing on December 10, 2020,

2 Pursuant to the rules of procedure, the date of the orders referenced in this

opinion reflect the date in which the order was docketed. See Pa.R.A.P. 108(b).

3 The home assessment was completed, and the report was filed on October

27, 2020.

4 The psychological screenings were completed, and the reports were filed on

November 5, 2020.

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the court granted Maternal Grandparents intervenor standing under Section

5325. See N.T. Hearing, 12/10/20, at 19. The court noted that “while I’m

granting it under 5325, it doesn’t mean that [Maternal Grandparents] might

not have it under 5324 now or going forward.” Id. at 19. After a conciliation

conference on January 14, 2021, an interim order was entered awarding

Mother, Father and Maternal Grandparents shared legal custody; Mother and

Maternal Grandparents primary physical custody; and Father partial physical

custody every other weekend and every Thursday. See Custody Order,

1/27/21.

On June 28, 2021, the scheduled date for the custody hearing, the

parties reached a custody agreement that kept the legal and physical custody

provisions of the interim order and included a provision that the parties agreed

to engage in family counseling with Kelly Hockenberry, Esquire, who was

directed to prepare a report for the review hearing. 5 See Custody Order,

6/28/21. The order was entered as a final custody order that superseded all

prior orders. Id. at 6. No appeal was taken.

Following a full-day review hearing, the court entered an order on

October 1, 2021, which clarified and allocated periods of physical custody and

parental responsibilities between Mother and Maternal Grandparents while

they resided in the same home. See Order, 10/1/21. All other aspects of the

June 28, 2021, order remained in effect. See id. at 3. No appeal was taken.

5 All parties were represented by counsel and signed the custodial agreement.

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On August 21, 2023, Mother filed a petition for emergency custody

asserting that Maternal Grandparents took the children to New Jersey during

Mother’s custodial time, failed to provide an address of where they were

staying and did not allow Mother to speak with the children. On August 29,

2023, Maternal Grandparents filed a petition to modify custody and an

emergency petition for special relief and requested temporary suspension of

the parents’ custodial rights pending hair follicle testing. 6 They alleged that

Mother and Father were increasingly hostile toward Maternal Grandparents

and failed to abide by the terms of the custody order. They also alleged that

they discovered what they believed were drugs and drug paraphernalia in

Mother’s bedroom and within reach of the children.

Following a conciliation conference on September 23, 2023, the

conciliator recommended awarding Maternal Grandparents sole legal and

physical custody of the children with Mother and Father having periods of

supervised visitation. Because the change of custody was not agreed upon,

Mother and Father filed their objections and requested a trial.

Thereafter, Mother and Father filed a variety of motions and petitions

challenging Maternal Grandparents’ standing and involvement in the custody

6 Their petition to modify included notice to Mother and Father that they “have

been sued in court to obtain custody of the child[ren.]” Notice and Order to Appear, 8/29/23. Revised petitions were filed on August 30, 2023, that included additional factual information, but did not change the requested relief. The revised petition to modify included the same notice to Mother and Father that they “have been sued in court to obtain custody of the child[ren.]” Notice and Order to Appear, 9/12/23.

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action. Several hearings addressing the parties’ filings were held by at least

three different judges until the Honorable Deborah S. Ryan was assigned to

the case. There were also several petitions for protection from abuse (“PFA”)

filed by Mother against Father, Mother against Maternal Grandparents, Father

against Maternal Grandparents7, and Maternal Grandparents against Mother 8.

We highlight the major hearings and changes to custody.

On October 5, 2023, a hearing on the recommended change in custody

and Maternal Grandparents’ emergency petition was held before the

Honorable Louis Mincarelli. Due to allegations made against Mother and

Father, coupled with their behavior in the courtroom, Judge Mincarelli ordered

Mother and Father to undergo immediate drug testing. The instant test

indicated that Mother was positive for methamphetamines and Father was

positive for amphetamines. Father indicated that he was prescribed Adderall,

but did not provide the court with a copy of his prescription. Thereafter, the

court entered an order awarding Maternal Grandparents sole legal and

physical custody of the children. See Order, 10/5/23. If Mother continued to

reside with Maternal Grandparents, she was to be supervised on an agreed ____________________________________________

7 On October 2, 2023, Father obtained a temporary PFA order which included

the children as protected parties. As a result, the children were removed from Maternal Grandparents’ home by police at 11:00 p.m.

8 On October 6, 2023, Maternal Grandparents obtained a temporary PFA, and

later a six-month final PFA, against Mother. The PFA evicted Mother from Maternal Grandparents home and she moved in with her paramour, John Canal, in New Jersey. It did not supersede the custody order except that Mother’s visits would be supervised by Child and Adolescence Counseling Services of Southeastern Pennsylvania

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upon schedule. Id. If Mother moved out, then her visits would occur at

Maternal Grandparents home every Sunday from 12:00 p.m. to 6:00 p.m.

under their supervision. Id. Father was to be supervised by Child First Family

Services every other Saturday from 12:00 p.m. to 3:00 p.m., or any other

three-hour block of time available to the agency. Id. Mother and Father were

both ordered to engage in and follow through with mental health and drug

and alcohol treatment programs, and to provide documentation of such. Id.

On December 12, 2023, Mother filed a notice of proposed relocation to

Mount Laurel, New Jersey. Maternal Grandparents filed a counter-affidavit

objecting to the proposed relocation. The custody hearing was scheduled

before the Honorable Analisa Sondergaard for June 2024, with a pretrial

conference scheduled for April 2024.

Prior to then, a hearing on Mother’s petition for special relief was held

on April 8, 2024, before the Honorable Alita Rovito. Judge Rovito dismissed

Mother’s petition and entered an interim order which amended the October 5,

2023, order and the most recent PFA order only in the following manner: Child

First Family Services would now supervise Mother’s visits every Saturday for

four hours at a location designated by Child First. 9 See Order, 4/9/24. Father

agreed to move his supervised visits to Sunday. Id.

9 The order also stated that (1) the contempt issues would be addressed in

the scheduled contempt hearing; (2) the PFA issues would be addressed in a hearing on Maternal Grandparents’ request to extend the PFA; and (3) the custody issues would be addressed during the scheduled custody trial.

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On May 7, 2024, Judge Sondergaard granted Father’s request for

recusal; therefore, the custody hearing was rescheduled to November 2024

before Judge Ryan.

A hearing was held on August 9, 2024, which addressed: (1) Mother’s

emergency motion for contempt filed March 25, 2024; (2) Mother’s motion to

modify interlocutory order for alternative paid supervision service filed June

10, 2024, emergency motion to modify interlocutory order/request for change

in supervision filed June 18, 2024, and petition for special relief filed July 16,

2024, all of which requested a change in the terms of the custody order; (3)

Maternal Grandparents petition for counsel fees against Mother; and (4) John

Canal’s petition to intervene. The court took the matters under advisement

at the end of the hearing.

On August 28, 2024, the court issued multiple orders. First, a temporary

custody order wherein Mother was awarded four hours of supervised custody

on Sundays if it occurred in New Jersey, and six hours if it was in Pennsylvania.

The court also ordered (1) Mother to complete drug and alcohol and

psychological evaluations with Dr. V. Richard Roeder; (2) the parties to

attempt to agree on a non-professional supervisor for Mother’s time and

provided recourse if no agreement was reached; and (3) an in-home visit and

evaluation of John Canal’s residence. The order further provided that if all

conditions were met, it would approve John Canal as a non-professional

supervisor and Mother would be able to exercise her custodial time in New

Jersey.

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Second, an award of partial counsel fees ($3,571.87) to be paid by

Mother to Maternal Grandparents. Third, an order denying Mother’s petition

for contempt, but providing Mother five “make-up” visits with the children.

Fourth, an order denying John Canal’s petition to intervene.

On September 5, 2024, Mother filed an appeal from each order, as well

as a request for reconsideration.10 Said request was denied. Due to Mother’s

appeals to this Court, the custody trial was rescheduled to January 2025.

The in-home evaluation of John Canal’s residence was submitted to the

court on October 15, 2024. On October 21, 2024, after a colloquy, the court

entered an amended interim order appointing John Canal as supervisor of

Mother’s custodial time with visits to occur every Sunday from 12:00 p.m. to

6:00 p.m. in a public setting in Pennsylvania. See Orders, 10/21/24 &

11/22/24. The order also directed Mother to comply with the previous order

for drug and alcohol and psychological evaluations. Id.

A six-day custody hearing was held from January 27, 2025, through

February 3, 2025. Father and Maternal Grandparents were represented by

counsel, and Mother was pro se. At the outset of the hearing, the court noted

that it would not revisit the 2020 order granting Maternal Grandparents’

standing. N.T. Custody Hearing, 1/27/25, at 6. However, it would assess

whether they continued to have standing at that time. Id. The court then

asked each party what relief they were requesting. Mother sought primary ____________________________________________

10 Mother’s appeals were ultimately quashed or dismissed. See 2486-2489 EDA 2024.

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physical custody with Father having partial physical custody, and the Maternal

Grandparents removed from the case. Id. at 10. Father likewise sought

primary physical custody with Mother having partial physical custody, and the

Maternal Grandparents removed. Id. at 22. Maternal Grandparents

requested that sole legal and physical custody remain with them, subject to

supervised visits with the parents. Id. at 27.

The court heard testimony from the following witnesses: Mother, Father,

Maternal Grandmother, Maternal Grandfather, Brooker Berger (Mother’s

friend), Chris Pawlowski (probation officer), Kim Melhorn (owner of Child

First), Angela Gornish (supervisor of Father’s visits), Tracey Azzolini (Father’s

friend), John Canal, Dr. Blumenthal (medical review officer), and Carol

Gamber (Paternal Grandmother).

On February 28, 2025, the court entered an interim custody order and

order directing expert examination and report, as well as an extensive opinion

analyzing both the custody and relocation factors. See Interim Order and

Opinion, 2/28/25. The court awarded Maternal Grandparents with sole legal

and primary physical custody of the children. Father was required to complete

a home evaluation prior to resuming supervised visits in his home. Mother

was awarded supervised visitation every Sunday from 10:00 a.m. to 6:00

p.m. with John Canal as her supervisor. If Mother completed her court-9-J-A10006-26

ordered evaluations, the court would expand Mother’s custodial time. 11

Additionally, the court explicitly denied Mother’s request to relocate the

children to New Jersey.

The order also prohibited the parties from filing frivolous, nonemergency petitions. Despite this prohibition, Mother and Father filed

numerous pleadings titled “emergency” requesting the court to certify the

February 28, 2025, interim custody order as an appealable interlocutory order.

The requests were denied.12 Mother also filed several “emergency” pleadings

requesting funds to complete her court-ordered evaluations.

Mother was evaluated by Dr. Roeder on June 10, 2025, and a report was

issued on June 19, 2025. A review hearing was held on June 23, 2025, the

focus of which was the parties’ compliance with the February 28, 2025, order.

The order scheduling the review hearing did not set forth the parameters of

the hearing or provide notice that the court would reconsider Mother’s request

to relocate. The court heard testimony from: Dr. Roeder, Mother, Father, and

Maternal Grandmother.

On July 3, 2025, the court entered a final custody order and an extensive

opinion analyzing both the custody and relocation factors. See Final Custody ____________________________________________

11 The order provided Mother with an opportunity to choose her own provider

to complete the drug and alcohol and mental health evaluations. If, however, the provider was not approved by the court, then she was required to complete the evaluations with Dr. Roeder as originally ordered in August 2024.

12 Despite the court’s order denying her request for an interlocutory appeal,

Mother filed four notices of appeal of the February 28, 2025, order, which were dismissed or quashed. See 886-889 EDA 2025.

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Order and Opinion, 7/3/25. The final order modified the interim order

changing primary custody to Mother on a gradual basis. Mother and Maternal

Grandparents would share legal custody until Mother assumed primary

physical custody, then Mother would have sole legal custody. Mother’s

supervision requirements were removed, and the court imposed a schedule

gradually increasing Mother’s custodial time until she assumed primary

physical custody on August 4, 2025. Once Mother assumed primary physical

custody, Maternal Grandparents were awarded partial physical custody every

other weekend. Father’s supervised visits were dependent on his completion

of a home evaluation, as well as the previously ordered mental health and

drug and alcohol evaluations.13 By changing primary custody to Mother, who

resides in New Jersey, the court implicitly granted a relocation.

Maternal Grandparents filed a motion for reconsideration and stay of the

order pending appeal, as well as a petition for special relief. The motions were

denied. This timely appeal followed. Maternal Grandparents raise the

following issues for our review:

1. The trial court’s order modifying all aspects of custody without

notice is a violation of the parties’ due process rights as no

modification petition was pending and school change and

relocation had already been denied.

2. It was an abuse of discretion and not in the best interest of the

children to sua sponte grant a change of schools, as well as

uproot all stability in their family and community lives.

13Between the six-day custody hearing and review hearing Father sold his home. As of June 2025, Father resided in Philadelphia with his brother and had not provided his address to Mother or Maternal Grandparents.

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3. The trial court abused its discretion when it ordered a change

in legal and primary physical custody because the children (and

mother) will lose their health insurance and social security

benefits.

4. It is an abuse of discretion to rely on the stated preference of

a six and nine year old child is not outweighed by their

developmental stage, maturity levels and judgment.

5. The psychological assessment is not an accurate tool for

determining safety for mother to parent, and does not address

her psychiatric concerns.

Appellants’ Brief, at 9.

Our analysis is focused on the first issue as it is dispositive of this appeal.

We take no position on the remaining issues.

Maternal Grandparents argue that the July 3, 2025, order implicitly

granting Mother’s request to relocate was a violation of their due process

rights because they were not provided notice that the issue of relocation would

be addressed during the review hearing. “A question regarding whether a due

process violation occurred is a question of law for which the standard of review

is de novo and the scope of review is plenary.” S.T. v. R.W., 192 A.3d 1155,

1160 (Pa. Super. 2018). It is well settled that “procedural due process

requires, at its core, adequate notice, opportunity to be heard, and the chance

to defend oneself before a fair and impartial tribunal having jurisdiction over

the case.” S.T., 192 A.3d at 1161.

A parent seeking to relocate a child’s residence must provide notice to

“every other individual who has custody rights to the child.” See 23 Pa.C.S.A.

§ 5337(c). If a party objects to the relocation, the court must hold a hearing

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and consider whether relocation is warranted after considering the statutory

relocation factors, given “weighted consideration to those factors which affect

the safety of the child.” Id., § 5337(g), (h).

Mother filed her notice of proposed relocation on December 12, 2023.

Maternal Grandparents filed their objection. The issue of relocation was

addressed during the six-day custody trial in early 2025. Mother presented

evidence of where she lived, as well as the school district the children would

attend if relocation to New Jersey was granted. After the close of trial, the

court issued a comprehensive opinion addressing the relocation factors (as

well as the custody factors) and an order denying Mother’s request to relocate.

Within the order, the court included a provision to schedule a review

hearing:

A review hearing shall be scheduled in this matter by Family Court

Administration no earlier than ninety (90) days following entry of

this Interim Custody Order on the docket and in accordance with

the court’s availability. The review hearing may include

consideration by the court of an increase in Mother and

Father’s custodial time, subject to their compliance with

and the results of the evaluations required herein.

Interim Custody Order, 2/28/25, ¶ 12 (emphasis added). After the denial of

Mother’s request to relocate, she did not file another notice of proposed

relocation. Moreover, the letter scheduling the review hearing did not provide

notice that the court was going to reconsider its denial of Mother’s request to

relocate. It merely stated: “Please be advised the above-captioned matter

has been scheduled for hearing on Monday, June 23, 2025 at 9:30 am in

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Courtroom 3 before the Honorable Deborah S. Ryan.” Family Court Letter,

3/13/25. Thus, neither Mother nor the court provided Maternal Grandparents

with notice that relocation would be considered during the review hearing, a

violation of their due process rights.

Because the July 3, 2025, order provides Mother with primary physical

custody, and Mother resides in New Jersey, the court implicitly granted Mother

permission to relocate. Since there was no notice of proposed relocation

pending, and the provision in the February 27, 2025, order regarding the

review hearing did not mention that relocation was still at issue, we conclude

that the court abused its discretion. As such, we vacate the July 3, 2025,

order, and remand for imposition of the February 28, 2025, order as a final

order.

July 3, 2025, custody order vacated. Case remanded. Jurisdiction

relinquished.

Date: 9/1/2026

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