In re the Marriage of Brink

Mother appeals an order that modified an original custody award by changing custody of the parties’ three minor children to father. Father’s motion to modify was precipitated by mother and the children moving to California. His motion was in the alternative: to award him custody or that mother be required not to change her residence or that of the children from the Albany-Lebanon area without court approval. The trial court found that there had been a “significant change of circumstances” and awarded father custody. We review de novo and reverse.

The marriage of the parties was dissolved in…