The Superior Court of Pennsylvania has vacated a custody order involving parents Francis Snyder and Christina Hryhorchuck, ruling that the trial court violated Hryhorchuk's due process rights. The court's decision, filed on October 26, 2026, centers on the use of evidence that was not properly admitted during the custody hearings, impacting the custody of their child, R.S., born in March 2023.

This ruling is significant as it underscores the importance of adhering to legal procedures in custody cases, ensuring that both parties have a fair opportunity to present their cases. The decision affects not only Hryhorchuk and Snyder but also sets a precedent regarding the admissibility of evidence in custody disputes.

Background

The parties in this case are Francis Snyder and Christina Hryhorchuk, who have been engaged in a custody battle over their child, R.S. In April 2024, Snyder filed a complaint for custody, followed by Hryhorchuk's similar filing the next month. The case progressed through numerous motions and a multi-day custody hearing that took place over several months, culminating in a final hearing on March 6, 2026.

During the proceedings, the court ordered both parents to undergo psychological evaluations and a substance abuse evaluation. However, neither party submitted the reports from these evaluations into evidence, nor did the evaluators testify during the hearings. Despite this, the trial court admitted a redacted version of Hryhorchuk's psychological evaluation report, which was incomplete and did not include the full context necessary for a fair assessment.

The Ruling

The court ruled in favor of Hryhorchuk, agreeing that the trial court had indeed violated her due process rights. Judge McLaughlin stated, "The trial court violated Mother’s due process rights when it considered and relied on evidence not admitted into the record." The ruling emphasized that due process requires that all evidence used in custody determinations must be properly admitted and subject to cross-examination.

As a result, the Superior Court vacated the custody order and remanded the case back to the trial court for a new custody hearing. The court ordered that this hearing should take place within 60 days of the ruling. The opinion highlighted that the trial court's reliance on unadmitted evidence significantly impacted the custody determination, necessitating a fresh review of the case.

Impact

This ruling has important implications for future custody cases in Pennsylvania. It reinforces the requirement that all evidence must be properly admitted and allows both parties the opportunity to challenge and cross-examine evidence presented against them. This decision ensures that custody determinations are made based on a fair and complete record.

Parents involved in custody disputes can take comfort in knowing that their due process rights are protected. The ruling may also lead to more stringent adherence to evidence rules in custody cases, as courts will be held accountable for ensuring that all evidence is properly vetted before making determinations that affect children's lives.

What's Next

The case has been remanded to the trial court for a new custody hearing. It remains to be seen whether either party will appeal the Superior Court's ruling or if any related cases will arise from this decision. The trial court must now conduct a hearing that complies with the legal standards set forth in this opinion.