Bower v. Reich

Under the Parenting Act of 1987, as In Re Littlefield recently held, a trial court entering an initial parenting plan may not “order the primary residential parent of a child to live in a particular geographic area in order to facilitate frequent contact between the child and the other parent.”1 Guided by Littlefield, we hold a primary residential parent may invoke the “minor modification” provision of the Parenting Act when seeking court permission to move with the child to another state.

Erica Bower Reich was born in 1989, the only child of the marriage of Barbara Bower and David Reich. In…