The Fourth District partially reversed a judgment that awarded joint custody of children to parties, despite finding that the husband was a perpetrator of domestic violence, triggering the presumption of Fam C § 3044. The trial court failed to make specific findings in writing or on the record regarding how such presumption was rebutted. ![[D078652.PDF]] <!-- citation-library:start --> ## Citation reference Abdelqader v. Abraham (2022) 76 Cal.App.5th 186, 291 Cal.Rptr.3d 269 > [!info] Working notes > This is a personal working note. Citation details are for reference; opinion and current-status verification may still be pending. <!-- citation-library:end -->