What Are the Factors Which Determine Whether a Custodial Parent May Relocate to a Place Away from the Non-Custodial Parent ?
In Gruber v. Gruber, 400 Pa. Super. 174, 583 A.2d 434 (Pa. Super. 1990), our Court stated that, in every relocation dispute, the trial court must consider:
The custodial parent's desire to exercise autonomy over basic decisions that will directly affect his or her life and that of the children; a child's strong interest in maintaining and developing a meaningful relationship with the non-custodial parent; the interest of the non-custodial parent in sharing in the love and rearing of his or her children; and finally, the state's interest in protecting the best interests of the children.583 A.2d at 439. Our Court also set forth the following three factors relevant to the determination of whether a custodial parent may relocate to a geographical distance away from the non-custodial parent:
The potential advantages of the proposed move, economic or otherwise, and the likelihood that [the] move would improve substantially the quality of life for the custodial parent and the children and is not the result of a momentary whim on the part of the custodial parent; the integrity of the motive of both the custodial and non-custodial parent in either seeking the move or seeking to prevent it; and the availability of realistic, substitute arrangements which will adequately foster an ongoing relationship between the child and the non-custodial parent. Id.