In re Heinrich
Supreme Court of New Hampshire
7 A.3d 1158 (2010)
During their divorce, Mary Ellen Curotto (defendant) cross-petitioned to relocate their three sons to Florida for a managerial job at her family's hotel, while Eric Heinrich (plaintiff) opposed the move; a court-appointed guardian ad litem concluded the boys were closely bonded to both parents and that Heinrich's relationship with them would suffer if they relocated. The trial court granted the divorce, denied relocation, awarded Heinrich reimbursement for a child-support overpayment, and required a 48-hour third-party caretaker period before either parent could assume care, prompting Curotto's appeal.
Must a parent petitioning for the out-of-state relocation of a child demonstrate that the relocation is in the child's best interests and for a legitimate and reasonable purpose?