O'Gwynn v. Herbert - Pa. Superior Court, June 21, 2005
http://www.courts.state.pa.us/OpPosting/Superior/out/a16005_05.pdf
I haven't had a chance to fully analyze this case, but it involves both abuse and custody. It was decided under the old UCCJA -- which has been replaced with the UCCJEA -- along with the PPKA. So I'm not sure of its current relevance.
Donald Marritz, staff attorney
MidPenn Legal Services
Gettysburg, Pa.
