In re Marriage of Edlund & Hales

In In re Marriage of Edlund & Hales (1998) 66 Cal.App.4th 1454, the appellate court observed: "As to modifications of both initial and permanent custody orders, the Burgess court focused its analysis on the 'presumption in favor of stability and continuity in the child's primary custodial relationship.'" ( Id. at p. 1467.) Finally, the appellate court stated: "To summarize, then, the questions for decision with respect to a custodial parent's request for a move-away order are: (1) whether the custodial parent has sound, good faith reasons for the move; and (2) if so, whether the noncustodial parent can show that, as a result of the move, the child will suffer detriment rendering it essential or expedient for the welfare of the child that there be a change of custody. The showing of 'changed circumstances' required of the noncustodial parent must consist of more than the fact of the proposed move." ( Id. at p. 1469, )