## Facts

- Heidi Gatz (b. 1974) and Jason Gatz (b. 1979) were the children of Janet Steele Gatz and Mack Gatz.
- In October 1982, Janet was killed by multiple stab wounds inflicted by Mack, who pleaded guilty and was incarcerated.
- Heidi witnessed the killing; both children received psychiatric counseling and therapy.
- After the homicide, the children initially lived with their maternal grandparents, John and Edith Steele.
- A custody dispute developed among relatives, including the children’s paternal aunt and uncle, Frank and Sandra Heddings, and the Steeles.
- The trial court awarded primary custody to the Heddings and denied the Steeles primary custody, while permitting visitation.
- In later related proceedings, additional paternal relatives participated; the Steeles continued to seek primary custody through consolidated appeals.
- A central evidentiary dispute concerned testimony from multiple witnesses recounting statements by the deceased mother that her father, John Steele, sexually abused her as a child and impregnated her.

## Issues

1. Whether the trial court erred by admitting hearsay testimony repeating the deceased mother’s allegations that John Steele sexually abused and impregnated her.
2. Whether, considering the evidentiary rulings and the record as a whole, the trial court abused its discretion in denying the Steeles primary custody under the best-interests-of-the-child standard.

## Decision

- The Superior Court affirmed the orders denying the Steeles primary custody.
- The court upheld the admission and consideration of the challenged hearsay testimony concerning John Steele’s alleged incestuous abuse.
- The court held that the trial court did not abuse its discretion in concluding the children’s best interests were served by placement with paternal relatives rather than with the maternal grandparents.
- The court rejected the Steeles’ remaining procedural and evidentiary claims as lacking merit or nonprejudicial.

## Legal Principles

- The controlling standard in custody disputes among relatives is the best interests of the child, including the child’s emotional and psychological welfare.
- In custody proceedings, trial courts have substantial discretion in receiving and weighing evidence bearing on a proposed custodian’s fitness; appellate review is highly deferential.
- Hearsay statements of a deceased parent may be admitted and considered in a custody best-interests analysis when the statements are materially relevant to fitness and supported by reliability factors recognized in evidentiary law.
- An appellate court will not disturb a custody determination absent a clear abuse of discretion, particularly where the trial court’s decision rests on credibility assessments and fact-specific welfare findings.

## Conclusion

The Superior Court affirmed orders denying the maternal grandparents primary custody, holding that the trial court properly considered hearsay allegations by the deceased mother about the maternal grandfather’s past sexual abuse and did not abuse its discretion in placing the children with paternal relatives under the best-interests standard.


Heddings v. Steele, 496 A.2d 1166 (Pa. Super. Ct. 1985)