Ynclan v. Woodward

In the Ynclans' divorce trial, the judge privately interviewed the three oldest children, in camera, with only a court reporter present, to discern their custody preferences in a comfortable setting outside the parents' presence. Nolan (defendant) requested the transcript after the interviews, and his request was denied; Nancy (plaintiff) was granted the divorce and custody. Nolan appealed the transcript denial, though he had not filed an appeal challenging the custody decision itself.

Whether due process requires that a parent have access to the transcript of an in camera interview of his or her child in a custody determination, absent a pending appeal.