- General prayer for relief in Petition should put respondent on notice of issues to be presented at upcoming hearing, such as a request to determine custody.
- Failing to file an answer to a petition can serve to waive any defense to the original claim but will not waive the right to respond to a subsequent request not included in the petition.
- Respondents need reasonable opportunity to respond to new prayers for relief.
- Inadequate notice to respondent of issues in custody hearing can impede court’s ability to give proper consideration to issues impacting determination of child’s best interest.
- Despite a lack of transcript and appellant’s burden to show error from the record below, the Court determined that the trial court had abused its discretion.