Burgess v. Arnold

*257GEATHERS, J.:

**164In this child custody action, Brooke L. Arnold (Mother) seeks review of the family court's order awarding Maxie **165Burgess (Father) primary custody of their eight-year-old son (Son) should Mother relocate to Florida. Mother argues the family court erred by (1) creating a custody arrangement that penalizes Mother for relocating to Florida; (2) applying an initial custody analysis rather than a change-in-circumstances analysis; and (3) imposing a joint custody arrangement based on a finding that the parties had been operating under a joint custody arrangement prior to…