Court's Permission to Relocate Minor Children In Florida

In Janousek v. Janousek, 616 So. 2d 131 (Fla. 1st DCA 1993) in reviewing a trial court order that granted a wife primary residential responsibility and permitted her to relocate two minor children after a five-year period, the district court reasoned that "when a cause involving child custody is presented to the trial court, 'the trial court is required to make a final determination on that issue at that time.'" Id. at 132 (quoting Martinez, 573 So. 2d at 40). The district court noted that "no evidence was presented which would support a determination that a substantial change in circumstances would occur at the end of this five-year period or that such a relocation would promote the welfare of the children." Id. Accordingly, the district court vacated the relocation provision in the final judgment. See id.