In Yates v. Yates, 2008 PA Super 296, 963 A.2d 535 (Pa. Super. Ct. 2008), the Superior Court of Pennsylvania rejected the argument that the appointment of a parenting coordinator constituted an improper delegation of judicial decision-making authority. Id. at 540.
The trial court had resolved the primary issues relating to legal custody, physical custody, and visitation. Id.
The parenting coordinator was empowered merely to resolve "ancillary" custody disputes, such as "determining temporary variances in the custody schedule, exchanging information and communication, and coordinating [the daughter's] recreational and extracurricular activities." Id.
The appellate court held that, because the trial court had "resolved the central custody issues and retained judicial review over the parenting coordinator's decisions concerning the ancillary issues," there was not an improper delegation of judicial decision-making authority to the parenting coordinator. Id. at 541.
The court noted that, "if the parties are dissatisfied with the parenting coordinator's decision, they can appeal it to the trial court," which would review the contested decision de novo. Id.