Tomkins v. Tomkins

David Tomkins, the former husband/father, appeals an order allowing the former wife/mother to relocate to Ohio with the couple’s son. A primary residential parent’s request to relocate with a minor child is governed by section 61.13(2)(d), Florida Statutes (2003). Here, the trial court considered the evidence and the statutory criteria, finding that relocation was in the best interests of the mother and the minor child.

An appellate court’s standard of review of a trial court’s order regarding relocation is whether the trial court abused its discretion. We look to see if there is substantial…