Thompson v. Pafundi

¶ 1. Mother appeals the Washington Family Court’s award to father of physical and legal rights and responsibilities for the couple’s minor daughter. On appeal, mother contends: (1) the court violated her due-process rights when, without notice to her, it converted a hearing to amend temporary parent-child contact into a final determination of parental rights and responsibilities; (2) the trial court’s award of custody to father was a de facto award to the paternal grandparents; (3) the trial court erred in fatting to find a real, substantial, and unanticipated change in circumstances before…