The default case, yes. Here we are arguing of what the correct way of doing things should be. It is widely accepted in programming contracts to transfer the copyright to the client and in photography contracts it is otherwise.

bradly's case, like darkarmani pointed out is a communication issue. His wife assumed that since she is paying for the shoot she would own the resultant work. The photographer probably though otherwise and had a contract to back this up. For a contract to be considered legal there must be a "meeting of the minds" and clearly it didn't happen here. I blame the photographer here, because they usually have their own contract templates that they know well. They should correct any asymmetric of information that may result. Having the client hire a lawyer to examine the photo contract would be more expensive than hiring a photographer in the first place.

TL;DR If photographers don't want lawyers fees cutting into their service fees, they should be upfront about what they are peddling.