Falanga v. Boylan

The question in this case is not whether maintaining mother’s parental rights and responsibilities after her move to Georgia is in the child’s best interests. If he had been given the opportunity to present his case concerning the child’s best interests, father would have faced an uphill battle. We have recognized that at the best-interests stage of the modification analysis, “ ‘when a noncustodial parent seeks a change in custody based solely on the custodial parent’s decision to relocate, the moving party faces a high hurdle in justifying the violent dislocation of a change in custody from…