California, United States of America
The following excerpt is from Southern v. Southern, A149935 (Cal. App. 2017):
3. Although mother has not filed a respondent's brief defending the court's award of sole custody to her, father bears the affirmative burden of showing prejudicial error based on the record. (Smith v. Smith (2012) 208 Cal.App.4th 1074, 1077.)
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