Ramirez v. Holland

Ruben D. Ramirez appeals a court order permitting Lisa Holland to relocate to Indiana with their *326child, R.F.R., under the parental relocation statutes found at chapter 26.09 RCW. We hold that the trial court did not abuse its discretion in determining that Lisa was the parent entitled to the presumption in favor of relocation. We also hold, following the rationale of In re Custody of Osborne, 119 Wn. App. 133, 79 P.3d 465 (2003), that Ruben has not met his burden of showing that the statute violated his due process rights. We affirm.

Lisa Holland and Ruben Ramirez began living together in San…