Custody Hearings
Where the custody of a minor child is in dispute between a mother and father, a hearing should be had, whereby evidence on the question is adduced after the parties have had the opportunity to present testimony and each party as well as other witnesses is available for cross-examination. Henrikson v. Henrikson
A custody determination by a trial court is subject to an appeal by a reviewing court, and as the result of failing to have a separate hearing pertaining to custody, the appeals court is placed in the position of being unable to consider the evidence and examine the factors which led to the trial court’s decision. Henrikson v. Henrikson
Evidence of father’s unfitness was sufficient to require a hearing on the issue of child custody. Szewczyk v. Szewczyk

