F.T. v. L.J

In F.T. v. L.J. (2011) 194 Cal.App.4th 1, the reviewing court found a multitude of errors which revealed the family court did not understand the proper standards to apply in deciding the move-away motion, including the following: not addressing the question of which custody arrangement would be in the child's best interests; erroneously requiring the moving parent to show that the planned relocation was necessary; and focusing excessively on the detriment to the child's relationship with the nonmoving parent without considering the detriment to the child's relationship with the relocating parent if the child stayed behind. (Id. at pp. 21-26.) On the last issue, the reviewing court remarked that the family court cited only one In re Marriage of LaMusga (2004) factor to the exclusion of all the other LaMusga and other relevant factors. (Id. at p. 24.)