Sheree Hollandsworth v. Keith Knyzewski

Summary

The court held that a custodial parent's relocation with the children, standing alone, is not a material change in circumstances and that primary custodians are presumptively entitled to relocate. The noncustodial parent bears the burden of rebutting that presumption by showing that relocation would not serve the children's best interests, evaluated under specified factors. Applying that framework, the court concluded that the father failed to rebut the presumption and reversed and remanded for an order permitting relocation consistent with the opinion.