Adams v. Jack A.

Opinion

IKOLA, J.

Jack A. (father) appeals a postjudgment order awarding sole legal custody to Christina Adams (mother) of the parents’ only child, J. (now 14 years old). Because the court erred by refusing to remove an Evidence Code section 730 evaluator for bias and then relying on the evaluator’s biased report in awarding mother sole legal custody of J., we reverse the custody modification order.1 We also hold the court erred by denying father’s motion for the appointment of a special master and father’s request for a determination of the reasonableness of the section 730 evaluator’s fees.…