Dorsey v. Livramento (May 20, 2026)

Case details
Full caption
Brandy Dorsey v. Walter Livramento, III
Country
United States
Jurisdiction
Maryland (MD)
Court
Supreme Court of Maryland
Decided
May 20, 2026
Disposition
Affirmed
BRANDY DORSEY v. WALTER LIVRAMENTO, III, Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 1413152Only the Westlaw citation is currently available.UNREPORTED*Appellate Court of Maryland.BRANDY DORSEYv.WALTER LIVRAMENTO, IIINo. 2237 September Term, 2025|Filed: May 20, 2026Circuit Court for Anne Arundel County Case No. C-02-FM-15-000969Tang, Kehoe, S., Raker, Irma S. (Senior Judge, SpeciallyAssigned), JJ.OpinionOpinion by Tang, J.*1 This appeal arises from a motion to modify custody filedby the appellant, Brandy Dorsey (“Mother”). Following acontested hearing, the Circuit Court for Anne Arundel Countyfound a material change in circumstances but declined to granther sole legal and primary physical custody of the parties’minor child, as she requested. Instead, the court retained solelegal and primary physical custody with the appellee, WalterLivramento, III (“Father”). The court did modify Mother'svisitation and other provisions, which she does not contest.Mother's appeal focuses on the court's denial of sole legaland primary physical custody. She raises several issues in herinformal brief, which we summarize below. For the reasonsset forth herein, we affirm the judgment of the circuit court.BACKGROUNDMother and Father are the parents of a child born in 2015.They have been involved in ongoing custody litigation. Wesummarize the pertinent procedural history.In 2017, the court awarded Father sole legal and primaryphysical custody of the child, while granting Mother visitationevery other weekend. In September 2024, the parties entered aconsent order with the goal of “work[ing] towards a joint legaland shared physical custody arrangement.” Father continuedto have sole legal and primary physical custody of the child.The parties agreed to meet in six months to review the legaland physical custody arrangement, either together or with aparenting coordinator, in an effort to meet the goal.The consent order expanded Mother's alternating weekendvisitation. It also directed the parties to adhere to the holidayschedule established in a prior order from September 2017.Under the 2017 order, all holiday exchanges were to occur at alocal police station. Additionally, the parents were instructedto communicate civilly during exchanges. The consent orderfurther required the parties to comply with ten “kids’ rulesof separated families,” which include guidelines to preventdisparagement or conflict in front of the child.Additionally, the consent order required the parties tocommunicate with each other about the child via textmessages and notify each other of the child's medicalappointments and any event which significantly affected thechild's health, education, behavior, or general welfare.Mother's Motion to Modify CustodyIn December 2024, Mother filed a motion to modify theSeptember 2024 consent order. In the motion, Mother allegedthat since entering the consent order in September, the partieshad “experienced dispute and disagreement regarding theexchanges of the minor child.” She specified that Father hadnot complied with the order in the following ways:1[Father] continues non compliance with court orders whichis not in the best interest of our minor child. [Father]Refuses to communicate in regard to our child. Deniesto inform of pertinent information. [Father] continuallydenies access, Does not inform of appointments, Doesnot take to sports/events, Refuses to utilize [parentingcoordinator], Refuses holiday access, Refuses to follow the10 kids rules of separation. Refuses to consistently send ourchild to school creating struggles and decline. [Father] doesnot and has not ever had custody of our minor child and hasno interest in such. Does not parent or care for [the child] inany regard and has continually failed to demonstrate suchsince [the child's birth].
BRANDY DORSEY v. WALTER LIVRAMENTO, III, Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.2*2 Mother requested the court grant her “sole physical andlegal custody” of the child and reduce Father's access toevery other weekend. Father opposed the request, arguing thatno material changes occurred––Mother had made the sameclaims in motions to modify since 2017.The court scheduled a two-day hearing for October 9 and10, 2025, with both parties represented by their respectivecounsel. The court heard testimony from Mother; Father; andFather's mother, the child's paternal grandmother, MonicaJohnson (“Grandmother”). In addition, the court interviewedthe child outside the parents’ presence.Father testified regarding his employment as a truck driverand his work schedule, explaining that due to his hours, thechild stays with Grandmother during the school week andwith Father on weekends.The parties agreed that communication between them hadbroken down. Father did not cooperate with the parentingcoordinator as required by the order, and disputes aroseconcerning the child's health—specifically his hair loss,medications, and the sharing of information about medicalappointments. Each parent accused the other of withholdingthe child during their scheduled access times.Custody exchanges had become contentious. Mother andFather both presented the court with videos of differentexchanges occurring in November 2024, after the consentorder went into effect, to demonstrate the acrimonious natureof these exchanges. Mother introduced footage depicting anexchange involving Father that took place on November15, 2024. Father introduced a video showing an exchangebetween Mother and Grandmother at the police station onThanksgiving 2024.During the child's interview, the child described his livingarrangements: he stays at Grandmother's for one week, thenat Father's home for the weekend, then back to Grandmother'sfor another week, and finally at Mother's home. He alsotestified that during exchanges, Father attempted to speak toMother “about me, like if he's saying I need something or Ineed this medicine or something,” but Mother “just [ ] ignoreshim” and does not allow him to have the medicine.During closing arguments, Mother's attorney reiteratedthat the communication issues Mother and Father wereexperiencing constituted a material change in circumstances.Counsel addressed the Sanders-Taylor factors,2 arguing thatit was in the child's best interests for Mother to be awardedcustody. In contrast, Father's counsel contended that nomaterial change in circumstances had occurred, assertingthat Mother had made similar allegations against Father foryears. Counsel asked the court to keep sole legal and primaryphysical custody with Father.*3 At the conclusion of the hearing, the court found thatneither Mother nor Father complied with the pertinent orders.As to Father, the court found that he did not comply withthe requirement that the parties were to review the custodyarrangement after six months. The court found that Father“basically ignored [the requirement] because he didn't like it.”As to Mother, the court found Mother's demeanor in thevideos to be the “worst” evidence. The court recounted whatthe videos of the exchanges depicted:[G]randmother comes to the police station. She says oh, hehas some medicine or something, and I don't need to givethat to you. And then, [Mother], for some reason, starts tohave a fit about the fact that she talked about something thatthe child needed, rather than saying, oh, I understand, orsay nothing at all. And for some reason, [Mother] thoughtthat that was a positive thing for her.Just like ... the child exchange between [the parents], where[Mother] is hollering something out of the car. Then, shegets out. [Father's] talking to the child before the child'sgot to go, because I'm assuming [Mother's] hollering like amaniac. And then, she's thinking that this makes her lookgood. That was – those videos were the best evidence ofhow she behaves on a regular basis, and it's not acceptable.The court remarked that the videos that Mother thought were“good evidence” made her look “bad” and, later in the oralruling, indicated that Mother “can't control herself.” The courtfurther concluded it was “obvious” that the parents “can't getalong” and “communicate on a regular basis.”The court summarized the child's testimony, noting that hestays with Grandmother during the week and spends accesstime with his parents. The court characterized the child'sfeelings about this arrangement as “fine.”The court found a material change in circumstances. Inits decision, the court considered the parties’ ability tocommunicate, the “desire of the natural parents,” and various“school and social factors” relevant to the case. It modifiedthe prior orders—the September 2024 consent order and the
BRANDY DORSEY v. WALTER LIVRAMENTO, III, Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.3related September 2017 holiday visitation order. However, thecourt stated that these changes would not constitute “radicalmodifications.”The court ordered that primary physical and sole legal custodyremain with Father. It modified certain provisions relatedto visitation. In addition, both parents were required touse a communication application instead of text messagesto communicate about the child. The court also orderedthe parties to record video of the exchanges. Furthermore,the court reiterated the requirement to engage a parentingcoordinator.The court memorialized the oral ruling in an order enteredNovember 21, 2025. Mother moved for reconsiderationregarding the court's custody decision, which the courtdenied. Thereafter, she filed this appeal.We shall provide additional facts below as necessary.ISSUES PRESENTEDMother, now pro se, filed an informal brief. She presentsnumerous issues on appeal which she describes as follows:(1) Violation of the Custody Agreement; (2) ExcessiveSchool Absences and Exposure to Domestic Abuse; (3)Appellee's Alcohol Addiction and Non-Compliance withCourt Orders; (4) Child's Residence and Custody Location;(5) Parental Communication and Scheduling Issues; (6)Injuries Throughout and Following the October 10, 2025Ruling; (7) Appellee's Abandonment and Unavailability;(8) Inability to Manage Visitation and Schedules; (9) InCamera Interview Defects; (10) Appellee's Mother FalselyClaiming to Be The Child's Guardian; (11) The Judge Erredin Relying on Outdated Evidence by Failing to ConsiderPost-2024 Developments; (12) Violation of Due Process andRight to Be Heard in Clarifying Evidence; (13) Violation ofthe Maryland Rules of Procedure and Evidence Due to theIntroduction of Irrelevant and Late Evidence; (14) Violationof Maryland Rules Due to Introduction of Irrelevant andUndisclosed Evidence; (15) Violation of Maryland Law andProcedural Rules Due to Introduction of Expunged Recordsand Complaints; (16) Misinterpretation of Evidence andViolation of Procedural Fairness; (17) Monica's HarmfulActions and Misdiagnosis of Alopecia; (18) Best Interest ofthe Child Analysis.3PRINCIPLES OF APPELLATE REVIEW*4 Several issues and arguments raised by Mother are notproperly before us. Before proceeding to the discussion andto avoid repetition, we summarize the pertinent principles ofappellate review.BriefingMother filed an “Informal Brief” under this Court's December19, 2022 Administrative Order permitting informal briefingin family law cases where the appellant is a self-represented litigant. See Md. Rule 8-502(a)(9); AppellateCourt Administrative Order (Dec. 19, 2022). Although Rule8-502(a)(9) dispenses with the technical requirements of aformal brief under Rule 8-504, the informal brief still[M]ust identify issues that explain why the trial courterred or made a mistake in deciding the case and whythe decision should be reversed or modified. The issuespresented in the informal brief should be stated conciselywith a description of the facts surrounding the issue and anargument supporting the resolution of the issue.Guidelines for Informal Briefs (“Guidelines”) (b)(2)(emphasis added).4As this Court has consistently stated, “[w]e cannot beexpected to delve through the record to unearth factualsupport favorable to [an] appellant.” Van Meter v. State, 30Md. App. 406, 408 (1976). Nor is it our “responsibility toattempt to fashion coherent legal theories to support [an]appellant's sweeping claims.” Elecs. Store, Inc. v. CellcoP'ship, 127 Md. App. 385, 405 (1999). “[I]f a point germaneto the appeal is not adequately raised in a party's brief,the court may, and ordinarily should, decline to address it.”DiPino v. Davis, 354 Md. 18, 56 (1999); Klauenberg v. State,355 Md. 528, 552 (1999) (“[A]rguments not presented in abrief or not presented with particularity will not be consideredon appeal.” (emphasis added)).PreservationUnder Maryland Rule 8-131(a), we will ordinarily not decidean issue unless it plainly appears by the record to havebeen raised in or decided by the trial court. The purposeof this rule is to “require counsel to bring the position of
BRANDY DORSEY v. WALTER LIVRAMENTO, III, Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.4his client to the attention of the lower court at the trial sothat the trial court can pass upon, and possibly correct anyerrors in the proceedings.” Chimes v. Michael, 131 Md. App.271, 288 (2000) (citation omitted). “The rule is effectivelya form of estoppel—it curbs appeals that are inconsistentwith the parties’ positions at trial.” Id.; accord Halloran v.Montgomery Cnty. Dep't of Pub. Works, 185 Md. App. 171,202 (2009) (“[U]nless a [party] makes timely objections inthe lower court or makes his feelings known to that court, hewill be considered to have waived them and he can not nowraise such objections on appeal.” (citation omitted)); see, e.g.,Chimes, 131 Md. App. at 288 (holding the appellant “cannotargue now that the child support guidelines apply, because hedid not preserve that issue”); In re Tyrek S., 118 Md. App.270, 277 (1997) (determining the issue of appellant's inabilityto pay restitution was not preserved for review becauseit was not raised in appellant's exceptions to magistrate'srecommendation). If the argument is not preserved, we neednot address it. See, e.g., In re K.L., 252 Md. App. 148, 188n.36 (2021) (noting that where a party failed to argue theapplication of a specific standard before the magistrate andjuvenile court, such argument was not preserved and wouldordinarily not be addressed).Citations to Authorities*5 A party may, but is not required to, cite authorities in theinformal brief. See Guidelines, supra, at (b)(7). However, ifone does, the party should ensure that the authorities do, infact, exist and stand for the proposition stated. Submissionof nonexistent or inaccurate legal authority is improper andwastes judicial resources.Mother's brief contains numerous citations to cases and otherlegal authorities. We suspect that Mother may have usedgenerative artificial intelligence (“AI”) to assist in draftingher brief, as several cited authorities are fictitious, and othersdo not support the stated proposition.5 We identify theseproblematic citations in footnotes as relevant.In Mezu v. Mezu, 267 Md. App. 354 (2025), we highlightedthe potential dangers of using AI to conduct legal research orgenerate filings, including the risk of “hallucinated” citations.Id. at 367–68. Moreover, “[t]he citation of fake cases in abrief or other pleading filed with a court implicates multipleMaryland Rules.” Id. at 368. Attorneys who submit filingscontaining fake citations may be referred to the AttorneyGrievance Commission depending on the nature and severityof the misconduct. See id. at 374.Although there is no parallel disciplinary action for pro selitigants, Maryland Rule 1-311(c) authorizes us to strike theoffending filing. Where, as here, the filing is an appellant'sprincipal brief, striking it could result in dismissal underMaryland Rule 8-602(c)(5) for failure to file a brief. SeeMd. Rule 1-311(c) (“[T]he action may proceed as thoughthe [stricken] pleading or paper had not been filed.”); Md.Rule 8-602(c)(5) (court may dismiss appeal where brief is nottimely filed by appellant).We exercise our discretion to decline striking Mother'sinformal brief in its entirety. As explained below, severalissues are not properly before us, so we need not identify oraddress the problematic citations because we do not reach themerits of these issues. See infra, Parts I–III. However, thisdoes not excuse the impropriety of such conduct. To the extentan issue is properly before us, we will strike from the brief anycases that are fictitious and any authorities that clearly do notsupport the propositions for which they are cited. See infra,Part IV, notes 8–17. Mother is warned and put on notice thatcontinued citation of fabricated cases or misrepresented legalauthorities may result in sanctions, including the striking offuture filings in their entirety.With these principles in mind, we address the issues to theextent they are properly before us.DISCUSSIONWe first address the issues that are not properly before us. Wehave grouped them in the following parts: (I) UnpreservedIssues, (II) Inadequately Briefed Issues, and (III) Post-Hearing Issues. We address the merits of the remaining issues,which we group into Part (IV) Best Interest Analysis.I.UNPRESERVED ISSUESIssue 4Under Issue 4 (Monica's Harmful Actions and Misdiagnosisof Alopecia), Mother raises a sub-argument claiming that
BRANDY DORSEY v. WALTER LIVRAMENTO, III, Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.5the court “erred in accepting” the child's alopecia diagnosisdue to the absence of reliable medical evidence. Sheasserts that the diagnosing doctor had his medical licenserevoked. Citing Maryland Rule 5-702, Mother contends thatthe doctor's license revocation, combined with the “lackof supporting tests,” renders the diagnosis unreliable andtherefore inadmissible.*6 The argument is not preserved. Mother did not objectto any testimony regarding the child's diagnosis under Rule5-702 during the hearing, as she now does on appeal.6 Inany event, any error in admitting such evidence is harmless,because the court did not rely on this evidence in itscustody decision. See McKay v. Paulson, 211 Md. 90, 100(1956) (applying the “well established rule” that wrongfuladmission of harmless testimony is not reversible error);Beahm v. Shortall, 279 Md. 321, 330 (1977) (explaining theCourt's policy “not to reverse for harmless error”). At onepoint during testimony about the child's diagnosis, the courtremarked that it had:[N]o idea what he has because the father didn't take thechild back to the doctor. The child's hair fell out thelast time. So I don't know that. Neither does the father.Everybody's guessing because the child hasn't been back tothe doctor since the child's hair fell out.The court recognized that the “child [had] a history,” butreiterated that it had “no idea what the child's diagnosis isbecause ... the child hasn't gone back to the doctor.”Issue 9Under Issue 9 (In Camera Interview Defects), Motherargues that the court erred by “permitting the minor child'sstatements to be used in the proceedings without properlyaddressing the issue of privilege.” In addition, “[Father's]attorney's conduct in arranging for the [child's] therapist todrive the child to court, with the hidden agenda of instillingfear in the child, is highly problematic” because the attorney“effectively coerced and intimidated the minor.” She arguesthat the “court should have rejected the child's statements withthe therapist[ ] present due to the lack of a proper waiver ofprivilege and the manipulation of the interview process andpresence of a therapist in which [the child] already doesn'ttrust[.]”After the first day of the hearing, there was a discussionabout the court interviewing the child the next day. Thecourt expressed its intention to interview the child outsidethe parents’ presence, to which Mother's counsel agreed.The court further expressed its preference for conductingthe child's interview first thing in the morning and forarranging for the child to “come with somebody and leavewith somebody” so the child does not need to be in courtlonger than necessary. Mother's counsel responded, “Yeah, Iagree with you.”The following day, Father's counsel informed the court thatthe child's therapist, acting as a neutral party, had brought thechild to court. The court then asked the parties whether theywished for the therapist to be present in the courtroom duringthe interview. The court had previously stated that it wouldnot question the therapist, so patient-therapist privilege wasnot implicated.Mother's counsel expressed that “it would be better just”for the judge to speak with the child, which was Mother's“preference,” so that the child “completely speaks freely.”However, her counsel indicated that the therapist's presencewas “okay.” Father did not object to the therapist's presence inthe courtroom. Based on these responses, the court stated thatit would have the therapist “sit somewhere in the courtroomaway from [the child],” rather than “next to him.” Neither sideobjected to this approach.*7 The court conducted its interview with the child. After,the parties and their attorneys returned to the courtroom.Mother's counsel addressed the court about it interviewing thechild with the therapist present:[MOTHER'S COUNSEL]: My client has asked, and I don'tdisagree, that we were heard more robustly in terms of herobjection to the presence of the therapist speaking withYour Honor being -- while the minor child spoke with thetherapist present while speaking with Your Honor.THE COURT: Okay.[MOTHER'S COUNSEL]: My client is very concernedthat ... just given the nature of the custody schedule,the fact that the therapist does therapy within the homeof [Grandmother], and the privilege was not waived. Sofrankly, I'm not sure she should have been here, but I'mnot -- I wouldn't have any case law to support that atthis moment -- that the minor child really should havespoken with you alone, without fear of anyone overhearinghim. And we are asking that the [c]ourt consider asking to
BRANDY DORSEY v. WALTER LIVRAMENTO, III, Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.6speak with the child alone and without the presence of thetherapist –THE COURT: I've already spoken with him, so anythinghe says now is going to be tainted, number one. Numbertwo, I've spoken with him, and in my judgment, he wascompletely candid. He wasn't bothered by the therapist. Hedidn't even look at the therapist. They're accused when ...children [are] trying to seek answers from someone, thatwas not the case in this particular matter. He wasn't evenbothered by the therapist being here, nor was he -- nor inmy opinion, was he influenced by the therapist.[MOTHER'S COUNSEL]: I understand, Your Honor. Myclient –THE COURT: Your [c]ourt notes your objection.[MOTHER'S COUNSEL]: I appreciate you allowing me tomake the record, Your Honor.Mother's issue regarding the “interview defects” was notpreserved. First, Mother did not object to the therapisttransporting the child to court for the interview. Second,Mother did not object in a timely manner to the therapist beingin the courtroom during the interview. See Md. Rule 2-517(a)(“An objection to the admission of evidence shall be madeat the time the evidence is offered or as soon thereafter asthe grounds for objection become apparent. Otherwise, theobjection is waived ....”). Before the child was interviewed,Mother, through counsel, merely expressed her “preference”that the therapist not be present, but counsel indicated that itwas “okay.” “[U]nless a [party] makes timely objections in thelower court or makes his feelings known to that court, [s]hewill be considered to have waived them and [s]he can notnow raise such objections on appeal.” Caviness v. State, 244Md. 575, 578 (1966); see also Halloran, 185 Md. App.at 201(explaining that Md. Rule 8-131(a) arises from the principlethat “[w]hen a party has the option either to object or not toobject, his failure to exercise the option while it is still withinthe power of the trial court to correct the error is regarded asa waiver of it estopping him from obtaining a review of thepoint or question on appeal” (citation omitted)).Issues 12 & 16Under Issue 12 (Violation of Due Process and Right toBe Heard in Clarifying Evidence Facts), Mother arguesthe “judge's refusal to let [her] clarify the video violatedseveral principles of due process,” such as the “right to beheard and present [her] full defense,” the ability to presentthe presentation of relevant evidence, and her “right todefend [her]self in court.” She explains, “During the courtproceeding, [she] attempted to clarify a video where [her]actions were potentially misinterpreted,” “[t]he judge refusedto allow [her] to explain the video, even when it was crucial to[her] defense,” and “[t]his refusal effectively prevented [her]from presenting an important clarification or defense, directlyimpacting the fairness of the proceeding.”*8 Mother presents an overlapping argument under Issue 16(Misinterpretation of Evidence and Violation of ProceduralFairness). She argues that “[t]he judge's failure to interpretthe video accurately, create[d] a false narrative, anddisregard[ing] the context of my actions violated severalMaryland rules” and her “Due Process ... right to a fair trial.”Mother does not identify the point during the hearing in whichthe court purportedly refused to allow her to explain thevideo. We assume it was during the court's oral ruling whenit remarked that the video presented Mother in a bad light.There, the court stated:I have no idea why [Mother] thought that [the video] wasgood evidence on her behalf. I'm sure your lawyer probablytold you that, I – I'm not trying to show the judge this. Thisis bad. Evidence that you present is supposed to show youin your best light, not your worst light. So my question is,is that the best you could behave when you're not in court?Because that's the best evidence you presented regardingyour behavior. That's the best you can do when you're nothere. You thought it was good.At that point, Mother interrupted the court's oral ruling:[MOTHER]: May I -- may I speak, Your Honor?THE COURT: Ma'am, don't say anything. You thought –[MOTHER]: That's not true.THE COURT: I'm telling you how bad it looked because allI saw in both those videos was the mother -- [Grandmother]trying to tell you that the child needed certain things, andyou said, I don't say anything, don't say anything.Neither Mother nor her counsel objected on the grounds nowraised on appeal. Accordingly, these issues are not preservedfor review. See Md. Rule 8-131(a).
BRANDY DORSEY v. WALTER LIVRAMENTO, III, Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.7II.INADEQUATELY BRIEFED ISSUESUnder Issues 13 (Violation of Maryland Rules of Procedureand Evidence Due to the Introduction of Irrelevant andLate Evidence) and 14 (Violation of Maryland Rules Dueto Introduction of Irrelevant and Undisclosed Evidence),Mother argues that the court admitted evidence that wasirrelevant and not disclosed in discovery. Likewise, underIssue 15 (Violation of Maryland Law and Procedural RulesDue to Introduction of Expunged Records and Complaints),Mother argues that evidence of her “expunged record”and “complaints” should have been excluded, because theywere irrelevant, prejudicial, and were “introduced after thedesignated timeframe for evidence.”As we explained above, Subsection (b)(2) of the Guidelinesfor Informal Briefs states that the appellant must identifyissues “that explain why the trial court erred or made a mistakein deciding the case” and provide the Court “a description ofthe facts surrounding the issue and an argument supportingthe resolution of the issue.” Mother does not specificallyidentify which testimony or other evidence was improperlyadmitted. As we explained, “[w]e cannot be expected to delvethrough the record to unearth factual support favorable to [an]appellant.” Van Meter, 30 Md. App. at 408. Nor is it our“responsibility to attempt to fashion coherent legal theoriesto support [an] appellant's sweeping claims.” Elecs. Store,Inc., 127 Md. App. at 405. Accordingly, we decline to addressthese issues.7III.POST-HEARING ISSUES*9 Under Issue 6 (Injuries Throughout and Following theOctober 10, 2025 Ruling), Mother argues that the court did notaddress injuries sustained by the child while in Grandmother'scare, citing events that occurred after the hearing. Motheralso discusses post-hearing issues involving Grandmother'scare under Issue 4 (Child's Residence and Custody Location)to argue that the court erred in not granting custody to her.She explains that the child is unsafe under Grandmother'ssupervision. She cites an incident of alleged neglect byGrandmother that occurred after the court's oral ruling.Issues arising after the October 2025 merits hearing were notbefore the court when it issued the ruling that is the subject ofthis appeal. These post-hearing issues are best addressed byfiling a petition or motion with the circuit court and are notproperly brought before us in this appeal.IV.Best Interest AnalysisUnder Issue 18 (Best Interest of the Child Analysis), Motherargues that the court overlooked the best interests of thechild by denying her request for sole legal and primaryphysical custody of the child. She contends that the courtdid not properly address the following issues: violationsof the 2024 consent order (Issue 1);8 excessive schoolabsences and exposure to domestic violence (Issue 2);9Father's alleged alcohol addiction and noncompliance withcourt orders (Issue 3);10 the fact that the child was residingwith Grandmother (Issue 4);11 parental communication andscheduling issues (Issue 5);12 Father's abandonment of thechild and unavailability (Issue 7);13 Father's inability tomanage visitation and schedules (Issue 8);14 Grandmotherclaiming to be the child's guardian (Issue 10);15 and the child'salopecia diagnosis, which Mother claims is improper (Issue17).16*10 Under Issue 11 (The Judge Erred in Relying onOutdated Evidence by Failing to Consider Post-2024Developments), Mother contends that the court's reliance onevidence that pre-dated the September 2024 consent orderundermined its ability to determine the child's “true needs.”17Once the circuit court enters a child custody order, it maymodify that order if it “determines that there has been amaterial change in circumstances since the issuance of theorder that relates to the needs of the child or the abilityof the parents to meet those needs and that modifying theorder is in the best interest of the child.” FL § 9-202(a)(2025 Cum. Supp.). As such, the statute directs a two-step analysis on a motion to modify custody, whether ona permanent or temporary basis. Wagner v. Wagner, 109Md. App. 1, 28 (1996) (applying two-step analysis whenreviewing temporary custody order); see also McCready v.
BRANDY DORSEY v. WALTER LIVRAMENTO, III, Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.8McCready, 323 Md. 476, 480–81 (1991) (reviewing physicalcustody order under analysis).First, as a threshold question, the court must determine ifa material change in circumstances has occurred since theissuance of the custody order to be modified. Wagner, 109Md. App. at 28; see McCready, 323 Md. at 482. Second, “[i]f amaterial change of circumstance is found to exist, ... the court,in resolving the custody issue, considers the best interestof the child as if it were an original custody proceeding.”Wagner, 109 Md. App. at 28. In other words, the court mustdecide whether a modification of custody is in the child'sbest interest based on the changed circumstances, and thecourt must do so by considering the FL § 9-201(a) factorson the record or in a written opinion. See FL §§ 9-201(b),9-202(a) (2025 Cum. Supp.). Courts have wide discretion inmaking decisions about the best interests of children. Kadishv. Kadish, 254 Md. App. 467, 504–05 (2022) (citing Azizovav. Suleymanov, 243 Md. App. 340, 345 (2019)).The party seeking a change in custody bears the burden ofdemonstrating both the existence of a sufficient change incircumstances to justify that change and that a change incustody would be in the best interest of the child. Wagner,109 Md. App. at 30–31; Shunk v. Walker, 87 Md. App. 389,397–98 (1991) (explaining that “[t]he burden ... is clearly onthe party ‘who affirmatively seeks action by the [court]’ ” to“establish that the modification is necessary to safeguard thewelfare of the child” (citation omitted)).Mother does not seriously dispute the court's determination ofthe threshold issue—that a material change in circumstancesoccurred since the entry of the September 2024 order. Shealso does not argue that the court failed to consider thebest interest factors. Rather, Mother challenges the court'spurported failure to “address” or articulate certain best interestfactors in its ruling, and she disputes the court's weighing ofthe evidence in determining the custodial arrangement thatbest serves the child's interests.*11 Appellate review is not a forum for a disappointedparent to relitigate the weight of the evidence or dispute thecredibility of witnesses, because the circuit court “sees thewitnesses and the parties, hears the testimony, and ... is in afar better position than is an appellate court, which has onlya cold record before it, to weigh the evidence and determinewhat disposition will best promote the welfare of the minorchild.” Reichert v. Hornbeck, 210 Md. App. 282, 304 (2013)(citation omitted). As long as there is evidence to support thefactual findings and no abuse of discretion, we will affirm thatcourt's determinations regarding a material change and bestinterests. Gizzo v. Gerstman, 245 Md. App. 168, 203 (2020).The record reflects that the court considered the pertinentfactors based on the evidence presented and reached adiscretionary conclusion. The court found that the partieswere unable to communicate with one another regardingthe child's welfare. In determining whether a particularcustody arrangement is appropriate, the parties’ capacityto communicate and reach shared decisions regarding thechildren's welfare is paramount. Taylor v. Taylor, 306 Md.290, 303 (1986). Contrary to Mother's assertion otherwise,the court relied on evidence developed after the September2024 order was entered. The court was persuaded, particularlyby the videos taken after the September 2024 order, thatMother's behavior during exchanges was unacceptable. Thecourt found that she did not listen when the child's medicationwas discussed during exchanges and was unable to controlherself. Additionally, based on the child's interview, the courtindicated that the current physical custody arrangement was“fine.” We find no abuse of discretion in the court's decisionto deny Mother sole legal and primary physical custody.Moreover, “where the trial court must issue a statementexplaining the reasons for its decision, the court need notarticulate every step of the judicial thought process in order toshow that it has conducted the appropriate analysis.” Gizzo,245 Md. App. at 195–96. “Because trial judges are presumedto know the law, not every step in their thought processneeds to be explicitly spelled out.” Zorich v. Zorich, 63Md. App. 710, 717 (1985) (internal citation omitted). A trialcourt is not required “to articulate every fact upon which[it] relies,” as long as it sufficiently considers the relevantissues. Cousin v. Cousin, 97 Md. App. 506, 518 (1993); seealso Flanagan v. Flanagan, 181 Md. App. 492, 533 (2008)(“Under discretionary review, a trial judge's failure to stateeach and every consideration or factor does not, withoutdemonstration of some improper consideration, constitutean abuse of discretion, so long as the record supports areasonable conclusion that appropriate factors were taken intoaccount in the exercise of discretion.” (citation modified));see, e.g., Malin v. Mininberg, 153 Md. App. 358, 429 (2003)(explaining that, “[a]lthough consideration of the [statutory]factors [regarding a monetary divorce award] is mandatory,the trial court need not go through a detailed check list ofthe statutory factors” “because a judge is presumed to knowthe law” (citation modified)). The record indicates that thecourt was aware of the best interest factors and sufficiently
BRANDY DORSEY v. WALTER LIVRAMENTO, III, Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.9considered the relevant ones in deciding custody. “[T]he factthat the court did not catalog each factor and all the evidencewhich related to each factor does not require reversal.” AventisPasteur, Inc. v. Skevolifax, 396 Md. 405, 426 (2007) (citationomitted). For the reasons stated, we affirm the court's decisionto deny Mother's request for sole legal and primary physicalcustody of the child.*12 JUDGMENT OF THE CIRCUIT COURT FORANNE ARUNDEL COUNTY AFFIRMED. COSTS TOBE PAID BY THE APPELLANT.All CitationsNot Reported in Atl. Rptr., 2026 WL 1413152Footnotes*This is an unreported opinion. This opinion may not be cited as precedent within the rule of stare decisis. It may be citedfor its persuasive value only if the citation conforms to Rule 1-104(a)(2)(B).1Mother initially filed a motion to modify custody with the assistance of counsel. After her original counsel withdrew, shefiled a subsequent motion to modify on her own. She later retained new counsel to represent her.2In Montgomery County Department of Social Services v. Sanders, this Court articulated factors for consideration by acourt determining custody:The criteria for judicial determination includes, but is not limited to, 1) fitness of the parents, 2) character and reputationof the parties, 3) desire of the natural parents and agreements between the parties, 4) potentiality of maintaining naturalfamily relations, 5) preference of the child, 6) material opportunities affecting the future life of the child, 7) age, healthand sex of the child, 8) residences of parents and opportunity for visitation, 9) length of separation from the naturalparents, and 10) prior voluntary abandonment or surrender[.]38 Md. App. 406, 420 (1977) (internal citations omitted).In Taylor v. Taylor, the Supreme Court of Maryland listed factors for courts to consider, including the capacity of parents tocommunicate and to reach shared decisions affecting the child's welfare, willingness of parents to share custody, fitnessof parents, relationship established between the child and each parent, preference of the child, potential disruption ofchild's social and school life, geographic proximity of parental homes, demands of parental employment, age and numberof children, sincerity of parents’ request, financial status of the parents, impact on state or federal assistance, benefit toparents, and “all other circumstances that reasonably relate to the [custody] issue.” 306 Md. 290, 304–11 (1986). Thefactors in Sanders and Taylor are colloquially known as the Taylor-Sanders (or the Sanders-Taylor) factors. See, e.g.,Jose v. Jose, 237 Md. App. 588, 600 (2018) (considering Sanders-Taylor factors together).In May 2025, the General Assembly passed SB 548/HB 119, which codified the Sanders-Taylor factors, effective October1, 2025. The bill was enacted as § 9-201 in the Family Law article of the Maryland Code and was in effect at the timeof the merits hearing at issue in this appeal.3Mother's brief also designates the following as issues: (19) Standard of Review; (20) Conclusion; (21) Record SupportsCustody Award to Appellant; (22) Relief Requested. However, “Issues” 19–21 are a continuation of her Issue (18) BestInterest of the Child Analysis. “Issue” 22 is the relief she seeks from all the issues she presents on appeal.4The Administrative Order and the Guidelines for Informal Briefs can be found on the AppellateCourt's website. See Administrative Order, https://www.courts.state.md.us/sites/default/files/import/cosappeals/pdfs/adminorderinformalbriefs.pdf, [https://perma.cc/7Y28-CUY5]); Guidelines for Informal Briefs, App. Ct. Md.,https://www.courts.state.md.us/sites/default/files/import/cosappeals/pdfs/guidelinesinfor malbriefs.pdf, [https://perma.cc/NT67-7249] (last visited May 14, 2026).5In addition to her brief, Mother filed several motions with this Court in this case. In various motions, Mother cited casesthat do not exist.
BRANDY DORSEY v. WALTER LIVRAMENTO, III, Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.106Additionally, we note that the child's alopecia diagnosis was admitted during the hearing without objection. Mother testifiedthat the child was taken to the hospital at some point and diagnosed with alopecia. Additionally, Mother, through counsel,presented, and the court admitted, the child's medical records which contained the child's alopecia diagnosis.7Regarding Issue 15, if Mother is referring to an offense of identity fraud under $1,000, she may be confusing an “expungedrecord” with probation before judgment. During Father's testimony, over objection, he stated that he had learned Motherused his Social Security number to apply for credit cards, which led to Mother pleading guilty to identity theft. The courtclarified that it admitted this testimony solely to explain why Father did not share his home address with Mother and theninstructed Father's counsel to “move on” to another topic.Similarly, during Mother's testimony, Father's counsel asked if she had pled guilty to the offense, prompting an objectionfrom Mother's counsel. When Mother testified that she received probation before judgment, the court indicated “that'sa guilty plea” and then directed Father's counsel to “move on.” The court clearly did not rely on Mother's guilty plea inits custody decision, and any error in admitting this evidence was harmless. McKay, 211 Md. at 100 (applying the rulethat wrongful admission of harmless testimony is not reversible error); Beahm, 279 Md. at 330 (explaining the Court'spolicy “not to reverse for harmless error”).8We strike the portion of Mother's Issue 1 that states that “a parent's failure to comply with a custody agreement can justifya modification,” because the case she cites, Perry v. Perry, 94 Md. App. 735, 620 A.2d 953 (1993), does not exist. Thecitation to the Maryland Reporter is In re Jason W., 94 Md. App. 731, 619 A.2d 163 (1993), a case about a juvenile court'sauthority to order restitution. The citation to the Atlantic Reporter is Board of License Commissioners of Carroll Countyv. Pizza Hut of Maryland, Inc., 95 Md. App. 291, 620 A.2d 953 (1993), a case about a liquor store license.9We strike the portion of Mother's Issue 2 that states “custody arrangements must prioritize the safety and well-being ofthe child,” because the case she cites, Stein v. Stein, 297 Md. 113, 464 A.2d 1066 (1983), does not exist. The citationto the Maryland Reporter is Hearst Corp. v. Hughes, 297 Md. 112, 466 A.2d 486 (1983), a defamation case. The citationto the Atlantic Reporter is Grimes v. State, 297 Md. 1, 464 A.2d 1065, 1066 (1983), a criminal case about a victim'stestimony relative to criminal agency, given subsequent to hypnosis.10We strike the portion of Mother's Issue 3 that states “custody decisions must consider a parent's ability to provide a safeand stable environment,” because this assertion cites to the non-existent case, Stein, 297 Md. 113. See supra note 9.11We strike the portion of Mother's Issue 4 that states “custody arrangements must prioritize the stability and well-being ofthe child,” because this assertion cites to the nonexistent case, Stein, 297 Md. 113. See supra note 9.12We strike the portion of Mother's Issue 5 that states “effective communication and cooperation between parents areessential to the child's well-being,” because the case she cites for support, Baker v. Baker, 55 Md. App. 507, 462 A.2d86 (1983), does not exist. The citation to the Maryland Reporter is Norwood v. State, 55 Md. App. 503, 462 A.2d 93(1983), affirming rape convictions. The citation to the Atlantic Reporter is Gerald v. State, 55 Md. App. 483, 462 A.2d 85,86 (1983), a criminal case about an illegal sentence.13We strike the portion of Mother's Issue 7 stating “that custody decisions must prioritize the child's best interests,” becausethe case on which she relies, Stein, 297 Md. 113, does not exist. See supra note 9.14We strike the portion of Mother's Issue 8 stating “a parent's ability to manage the child's schedule and responsibilities iscrucial to ensuring stability and emotional well-being.” The assertion cites to the non-existent case, Baker, 55 Md. App.507. See supra note 12.15We strike the portions of Mother's Issue 10 as it pertains to her argument that “misrepresenting oneself as a child'sguardian or custodial parent without legal authority is a serious offense, carrying potential legal consequences,” because:• Maryland Family Law Article (“FL”) § 5-203, relied on by Mother, does not state that “guardianship or custodialrelationship must be legally established, and any false representation of such a relationship undermines the child'ssafety and welfare.”
BRANDY DORSEY v. WALTER LIVRAMENTO, III, Not Reported in Atl. Rptr. (2026) WESTLAW   © 2026 Thomson Reuters. No claim to original U.S. Government Works.11• Kaczorowski v. City of Baltimore, 309 Md. 505, 525 A.2d 628 (1987), an action challenging the continued existenceof the Baltimore Development Agency, does not stand for the proposition that “misrepresentation” about one'sstatus as a child's guardian “can lead to consequences that directly affect the child's well-being and safety.”16We strike the portions of Mother's Issue 17 as it pertains to her argument and sub-arguments alleging that the child wasmisdiagnosed with alopecia and explaining Grandmother's “manipulative” behavior because:• FL § 9-101, relied on by Mother, relates to abuse or neglect by a “party.” Grandmother was not a party to theproceeding.• Jones v. State, 390 Md. 118 (2005), cited by Mother, does not exist. The case found at the principal citation is MotorVehicle Administration v. Weller, 390 Md. 115 (2005), the review of an administrative hearing involving suspensionof a driver's license.17We strike the portions of Mother's Issue 11 as it pertains to her argument that the court relied on stale evidence thatFather presented because of the following citation irregularities:• FL § 9-101 does not state that custody decisions “can only be determined with up-to-date evidence.”• Shurupoff v. Shurupoff, 307 Md. 113 (1986), does not exist. The case found at the principal citation is Ford v. Ford,307 Md. 105, 113 (1986), holding that the “slayer rule” did not apply to a beneficiary who murdered her motherbecause she was insane at the time of the crime.• Tucker v. Tucker, 339 Md. 284 (1995), does not exist. The case found at the principal citation is Hill v. State, 339Md. 275, 284 (1995), a cocaine distribution case.End of Document© 2026 Thomson Reuters. No claim to original U.S.Government Works.
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