Edmonds, S. v. Smith, J.
CourtSuperior Court of Pennsylvania
Date FiledOctober 20, 2026
Docket390 EDA 2026
JudgeBender
StatusUnpublished
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Full Opinion
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NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37
STEPHANY MARIE EDMONDS : IN THE SUPERIOR COURT OF
: PENNSYLVANIA
:
v. :
:
:
JAHLIL OLAJUWAUN SMITH :
:
Appellant : No. 390 EDA 2026
Appeal from the Order Entered January 14, 2026
In the Court of Common Pleas of Philadelphia County Domestic Relations
at No(s): 22-09321, PACSES: 930301873
BEFORE: SULLIVAN, J., BECK, J., and BENDER, P.J.E.
MEMORANDUM BY BENDER, P.J.E.: FILED OCTOBER 20, 2026
Appellant, Jahlil Olajuwaun Smith (Father), appeals pro se from the
January 14, 2026 order denying his motion for modification of an existing child
support order. Father argues that defective service of the complaint for child
support deprived the trial court of personal jurisdiction over him. After review,
we affirm.
The trial court set forth the relevant facts and procedural history of this
matter in its March 10, 2026 opinion. See Trial Court Opinion, 3/10/26, at 1-
3. Briefly, this child support matter originated on December 16, 2022, when
Stephany Marie Edmonds (Mother) filed a complaint seeking support for two
minor children, J.O.A.S., who was born in September of 2012, and S.M.S.,
who was born in July of 2014. The parties attended a pre-trial conference on
February 21, 2023, followed by a hearing before a Support Hearing Officer
(SHO) on June 21, 2023. The SHO issued a proposed order on July 14, 2023,
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and a final support order for the children was entered on August 11, 2023.
See id.
On October 25, 2023, Father filed a petition to terminate support for
both children. At the SHO hearing held on April 11, 2024, both parties
appeared; however, Father declined to answer any questions concerning his
income, assets, or expenses. The SHO recommended denying Father’s
petition, and Father timely filed exceptions to the SHO’s proposed order.
Following a hearing attended by both parties, the trial court denied Father’s
exceptions on August 16, 2024. Father filed a petition for reconsideration,
which the trial court denied on September 11, 2024. See id.
Father subsequently filed a petition to modify or terminate support on
November 10, 2025, and the trial court denied Father’s petition in an order
filed on January 14, 2026. Father filed a motion for reconsideration on January
22, 2026, which the trial court likewise denied. Thereafter, Father filed a
timely notice of appeal. Both the trial court and Father have complied with
Pa.R.A.P. 1925. See id.
On appeal, Father presents the following issues:
I. Whether the trial court lacked personal jurisdiction where
the certified record contains no proof of service of original
process?
II. Whether the trial court erred in applying res judicata without
jurisdiction?
III. Whether [Father’s] due process rights were violated?
Father’s Brief at 7 (some formatting altered).
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At the outset, we observe that Father’s brief fails to comply with the
Pennsylvania Rules of Appellate Procedure, which states that “[t]he argument
shall be divided into as many parts as there are questions to be argued[.]”
Pa.R.A.P. 2119. “Although this Court is willing to liberally construe materials
filed by a pro se litigant, pro se status confers no special benefit upon the
appellant. To the contrary, any person choosing to represent himself in a legal
proceeding must, to a reasonable extent, assume that his lack of expertise
and legal training will be his undoing.” Norman for Est. of Shearlds v.
Temple U. Health Sys., 208 A.3d 1115, 1118-19 (Pa. Super. 2019) (citation
omitted). Here, Father raises three issues in his statement of questions, see
Father’s Brief at 7, but the argument section of Father’s brief is separated into
six sections. See id. at 10-13. We note that compliance with our Rules of
Appellate Procedure is mandatory and failure to comply may result in dismissal
of the appeal. See Jacobs v. Jacobs, 884 A.2d 301, 305 (Pa. Super. 2005).
However, because our appellate review is not precluded, we decline to dismiss
the appeal on this basis. See id.
Father’s issues rest entirely on his assertion that the trial court lacked
personal jurisdiction due to an alleged defect in the service of original process,
and therefore, the court was powerless to enter any order or judgment against
Father. See Father’s Brief at 10-13. While Father argues that he “repeatedly
raised lack of service and lack of personal jurisdiction, including as early as
2023 and again during subsequent proceedings,” id. at 11, he fails to include
any record citations supporting this claim. Therefore, Father has waived the
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issue and no relief is due. See Commonwealth v. Harris, 979 A.2d 387,
393 (Pa. Super. 2009) (stating “[w]hen an allegation is unsupported any
citation to the record, such that this Court is prevented from assessing th[e]
issue and determining whether error exists, the allegation is waived for
purposes of appeal”); Milby v. Pote, 189 A.3d 1065, 1079 (Pa. Super. 2018)
(providing that it is not this Court’s responsibility to scour the record to find
documents that may support an appellant’s argument).
In any event, objections to service of process and personal jurisdiction
must be raised in preliminary objections filed within 20 days of service of the
complaint, and the failure to file preliminary objections renders the challenge
waived. Wagner v. Wagner, 768 A.2d 1112, 1119 (Pa. 2001) (citing
Pa.R.C.P. 1026, 1028, 1032(a)); see also Silver v. Thompson, 26 A.3d 514,
517, n.6 (Pa. Super. 2011) (stating “[a] party who fails to object to service of
process in preliminary objections waives that claim”). Father did not file
preliminary objections. Thus, Father’s argument concerning service of process
and personal jurisdiction is waived on this basis as well. See Wagner, 768
A.2d at 1119; Silver, 26 A.3d at 517, n.6.
For the above reasons, we conclude that Father waived his challenge to
service and personal jurisdiction. Accordingly, we affirm the order denying
Father’s motion for modification or termination of child support.
Order affirmed.
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Date: 10/20/2026
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