Rogers v. Parrish

¶ 1. In Hawkes v. Spence we addressed the “seemingly irreconcilable conflict” that arises when a “custodial parent’s interest in building a new life with the children” in a distant location is “pitted against the noncustodial parent’s interest in maintaining a close relationship with the children.” 2005 VT 57, ¶ 1, 178 Vt. 161, 878 A.2d 273. While acknowledging that “there is no precise formula” for resolving such conflicts, we adopted a governing standard and a nonexclusive list of relevant factors that trial courts must apply in determining whether a reexamination of parental rights and…