The Pennsylvania Superior Court dealt with an unfortunate confluence of a hyper-litigious party and two parents who could not resolve their disagreements over custody of their infant child. Before the child was a year old, Father filed a complaint for primary custody, but at the time, Mother had custody. Mother claimed that Father was violent and not fit to have custody. A hearing officer agreed with Mother and left the child in her primary custody during the pendency of the litigation. Soon thereafter, Father filed an application for special relief, which was denied. Not to be deterred, in less than one year, Father filed eight more applications for special relief. Some were denied, others were granted in part or whole. Eventually, the lower court awarded Mother $3,200 in counsel fees because she had to constantly defend herself from the vexatious litigation. Father appealed the award of counsel fees. The Superior Court reversed. The Court noted that both the Domestic Relations Code and Judicial Code permitted awarding counsel fees where a party engages in dilatory, obdurate, vexatious, arbitrary, or bad faith tactics. But here, Father’s petitions did not fall within any of those categories.