The court is capable of understanding that a custodial parent's interest in making decisions for the family's benefit and the noncustodial parent's concern in maintaining a close relationship with the child usually do not come in harmony, so to avoid these unfounded changes in custody, the standards provided by the law are stringent.
The non-relocation parent who wants to change to the custody arrangement must present that there has been a real, substantial, immediate and unexpected change of circumstances. A mere relocation is not sufficient to satisfy this requirement, and so, the parent must demonstrate that the relocation will adversely affect the child’s best interest.