Robinson v. Singleton - Child Support Appeal
Summary
The Superior Court of Pennsylvania issued a combined opinion in Robinson v. Singleton, concerning a child support appeal. The court remanded the case with instructions, noting procedural issues with the trial court's order and opinion.
What changed
The Superior Court of Pennsylvania issued a non-precedential decision in Robinson v. Singleton, remanding a child support order from the Lehigh County Court of Common Pleas. The appeal was filed by the mother (pro se) challenging a trial court order that reduced the father's child support obligation by nearly 60%. The Superior Court noted that the trial court's order affirming the hearing officer's recommendation lacked substantive legal analysis and that the trial court's order directing the appellant to file a Rule 1925(b) statement did not contain the requisite notice to the parties.
This decision primarily impacts legal professionals involved in family law appeals in Pennsylvania. While the appeal itself is specific to the parties, the court's commentary on procedural deficiencies (lack of Rule 236(b) notice, insufficient trial court opinion) serves as a reminder of procedural requirements. Compliance officers should note the importance of proper notice and substantive legal reasoning in trial court orders, particularly in cases involving pro se litigants or appeals from support hearing officer recommendations. No specific compliance deadline or penalty is mentioned, as this is a judicial opinion on an appeal.
What to do next
- Review procedural requirements for trial court orders and opinions in Pennsylvania family law appeals.
- Ensure proper Rule 236(b) notice is provided to parties when ordering the filing of a Rule 1925(b) statement.
Source document (simplified)
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by Lazarus](https://www.courtlistener.com/opinion/10808593/robinson-a-v-singleton-t/about:blank#o1)
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March 13, 2026 Get Citation Alerts Download PDF Add Note
Robinson, A. v. Singleton, T.
Superior Court of Pennsylvania
- Citations: None known
- Docket Number: 2201 EDA 2025
- Precedential Status: Non-Precedential
Judges: Lazarus
Combined Opinion
by [Anne E. Lazarus](https://www.courtlistener.com/person/8236/anne-e-lazarus/)
J-A08007-26
NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37
ALTHEA ITISHA ROBINSON : IN THE SUPERIOR COURT OF
: PENNSYLVANIA
Appellant :
:
:
v. :
:
:
TAJIR CHAKIB SINGLETON : No. 2201 EDA 2025
Appeal from the Order Entered July 10, 2025
In the Court of Common Pleas of Lehigh County Domestic Relations at
No(s): DR-08-01075,
PACSES: 028110078
BEFORE: LAZARUS, P.J., PANELLA, P.J.E., and STEVENS, P.J.E. *
JUDGMENT ORDER BY LAZARUS, P.J.: FILED MARCH 13, 2026
Althea Itisha Robinson (Mother) appeals pro se from the trial court’s
order, entered in the Court of Common Pleas of Lehigh County, in this support
matter. After careful review, we remand with instructions.
On July 9, 2025, the trial court held a hearing on Mother’s exceptions to
the support hearing officer’s report and recommendation; Mother and Father
appeared pro se at the hearing. See Pa.R.C.P. 1910.12. On July 10, 2025,
the trial court overruled Mother’s exceptions and affirmed the hearing officer’s
report and recommendation that reduced Father’s child support obligation by
almost 60%, from $2,020.92 to $ 827.82. In its order, the trial court stated,
“[Mother] did not demonstrate that the Hearing Officer committed legal error
or abused her discretion.” Order, 7/10/25, at 1 n.1.
- Former Justice specially assigned to the Superior Court. J-A08007-26
Mother filed a timely pro se notice of appeal.1 The trial court ordered
Mother to file a Pa.R.A.P. 1925(b) concise statement of errors complained of
on appeal. Mother never filed a Rule 1925(b) statement; however, we decline
to quash the appeal despite the trial court’s suggestion that we do so. See
Trial Court Opinion, 9/23/25, at 1. Here, the trial court’s order directing
Mother to file a Rule 1925(b) statement does not contain the requisite
Pa.R.C.P. 236(b) notice to the parties on the docket. See Scheduling Order,
7/31/25, at 1. See also Pa.R.C.P. 236(b) (“[t]he prothonotary shall note in
the docket the giving of the notice” of entry of order); Schlag v. DOT, Bureau
of Driver Licensing, 963 A.3d 598 (Pa. Cmwlth. 2009) (where no Rule
236(b) notation on docket that licensee served with copy of Rule 1925(b)
order, licensee did not waive all issues on appeal for filing untimely Rule
1925(b) statement).
Moreover, the trial court’s opinion is devoid of any substantive law or
legal analysis explaining its reasoning for overruling Mother’s exceptions and
affirming the hearing officer’s recommendation. Although the trial court
acknowledges it must conduct an “independent review of the [hearing
officer’s] report and recommendation to determine whether they are
appropriate,” the court’s review consists of nothing more than generic
language stating that “the Support Hearing Officer’s recommendations and
1 We note, with disapproval, the fact that no docketed order in the certified
record on appeal indicates that Rule 236(b) notice was given to the parties.
We trust, upon remand, the prothonotary will ensure that the proper Rule
236(b) notice is given, and notated on the docket, going forward.
-2-
J-A08007-26
the record developed in front of the Hearing Officer reveal that the Hearing
Officer gave proper consideration to [Mother’s] claims . . . [and] issues . . .
in light of the limited evidence and testimony [Mother] provided, and in
conjunction with the information and testimony provided by [Father].” Trial
Court Opinion, 9/23/25, at 2-3. The court then summarily concludes that
“[t]he findings of the Hearing Officer and record of those proceedings further
reveal that the Hearing Officer gave due consideration to the issues raised
[Mother’s] motions for sanctions, a gag order, and to admit new evidence.”
Id.
In Rasmusson v. Rasmusson, 264 A.3d 387 (Pa. Super. 2021)
(Table),2 our Court was presented with a similar situation in a child support
appeal. There, our Court remanded the matter to the trial court to prepare a
supplemental opinion explaining its reasoning supporting the final support
order and its denial of appellant’s exceptions to the hearing officer’s report
and recommendation. Id. at 9-10. See id. (remanding for supplemental
opinion where trial court did not issue comprehensive Rule 1925(a) opinion,
concluded appeals were untimely, and requested this Court dismiss appeals,
despite fact docket did not indicate clerk gave requisite Rule 236(b) notice).
2 See Pa.R.A.P. 126(b) (non-precedential decisions filed after May 1, 2019,
may be cited for persuasive value).
-3-
J-A08007-26
Plagued by the same deficiencies as the Rasmusson panel,3 we hereby
remand this case to the trial court to file, within 20 days, an amended Rule
1925(b) order that includes proper Rule 236(b) notice and which directs
Mother to file a Rule 1925(b) statement. After Mother files her Rule 1925(b)
statement, the trial court shall, within 45 days, issue a supplemental Rule
1925(a) opinion that thoroughly addresses all issues Mother has properly
preserved for appeal. The prothonotary of this Court is directed to strike this
appeal from the March 17, 2026 argument list and, upon receipt of the trial
court’s supplemental Rule 1925(a) opinion, issue a supplemental briefing
schedule to the parties. At the conclusion of the supplemental briefing
schedule, the prothonotary shall list this case on the next available argument
panel sitting in Philadelphia.
Case remanded with instructions. Superior Court jurisdiction retained.
Case to be removed from March 17, 2026 argument list.
3 We also note, with displeasure, the fact that the certified record on appeal
is woefully deficient for purposes of appellate review. The record fails to
include, in part: the support complaint; any pre-existing support orders in
the matter; any motions to modify; the Hearing Officer’s report and
recommendation; the notes of testimony from the Hearing Officer’s hearing;
and Mother’s exceptions to the Hearing Officer’s report and recommendation.
While it is well-established that it is the appellant’s responsibility to ensure
that the certified record on appeal is complete for our review, see Fiore v.
Oakwood Plaza Shopping Center, Inc., 585 A.2d 1012, 1019 (Pa. Super.
1991), it is also the clerk of court’s duty to maintain a complete record for
purposes of appeal. See Pa.R.A.P. 1921; Pa.R.A.P. 1931.
-4-
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