Supreme Court of Delaware

Zimmerman, Caleb v. Felicia Da Costa

April 6, 2026

Summary

The Supreme Court affirmed the Family Court's order awarding Mother sole legal custody and primary residential placement after concluding that Father's claims of an unfair hearing, improper self-representation, and an unsupported best-interests determination lacked merit. The Court held that Father failed to establish preserved error, plain error, or an abuse of discretion in the Family Court's handling of exhibits, witnesses, and the custody determination. The Court also denied Mother's request for costs and attorney's fees because the appeal was not frivolous.