I suggest you read Ireland v. Ireland, 256 Conn. 413 (Aug. 18, 1998). and the subsequent CT. Supreme Court ruling in Ford v. Ford.
In Ireland, the parties had been awarded joint custody of the child with primary physical custody awarded to the mother. The child's mother sought to move to California in order to allow her new husband to take a computer consulting job after his previous consulting contract expired.
The trial court (Stanley, J.) denied the motion on the grounds that the child's father enjoyed a close relationship with the child, the move to California would substantially interfere with that relationship and would not be in the best interests of the child. Writing for a majority of the en-banc (fully-assembled) Supreme Court, Associate Justice Katz reversed the trial court and returned the case for further proceedings.
Justice Katz reasoned that the realities of divorce result in an alteration of the relationship between both parents and the child and it is not realistic to attempt to preserve completely the quality and nature of the relationship that the non-custodial parent enjoyed, especially if such preservation is at the cost of the custodial parent's ability to start a new life and financially support herself. Justice Katz also found it important to balance the interests of the old family unit against the interests of the new blended family unit which resulted from the custodial parent's second marriage.
The Court emphasized, however, that its analysis was predicated upon legitimate and proper motives for the move. If the purpose of the move was vindictive or to thwart or interfere with the relationship between the non-custodial parent and child, the court would consider such motives improper and would not sanction the move. 246 Conn. at 424.
The court held that the custodial parent who wishes to relocate the child bears the initial burden of demonstrating to the court that (1) the relocation is for a legitimate purpose and (2) that the proposed location is reasonable. Once the custodial parent establishes those elements, the burden shifts to the non-custodial parent to prove to the court that the relocation would not be in the best interests of the child. 246 Conn. at 428. The non-custodial parent bears the latter burden because he or she will have access to the information concerning distance, difficulty in maintaining visitation, etc., that would be relevant to the court's determination of the issue.
In order to determine the "best interests of the child," the Ireland court incorporated the multi-factored approach adopted by the New York Court of Appeals in Tropea v. Tropea, 87 N.Y.2d 727, 665 N.E.2d 145, 642 N.Y.S.2d 575 (1996). The court will consider:
each parent's reasons for seeking or opposing the move,
the quality of the relationships between the child and the custodial and non-custodial parents,
the impact of the move on the quantity and quality of the child's future contact with the non-custodial parent,
the degree to which the custodial parent's and child's life may be enhanced economically, emotionally and educationally by the move,
the feasibility of preserving the relationship between the non-custodial parent and child through suitable visitation arrangements, and
the negative impact, if any, from continued or exacerbated hostility between the custodial and non-custodial parents, and the effect that the move may have on any extended family relationships.
In Ford v. Ford [PDF], 68 Conn. App. 173, 789 A.2d 1104 (Feb. 12. 2002) the Appellate Court ruled that the Ireland analysis applies only to cases in which the relocation issue arises after the divorce has gone to judgment. The opinion was authored by Judge Dranginis, the former statewide chief judge for family matters and therefore the opinion should carry great weight. Judge Dranginis ruled that (1) relocation issues that exist at the time the couple is initially divorce are governed the the "best interest of the child standard," which is the general standard governing custody decisions; and (2) the Ireland burden-shifting scheme that was developed in post-divorce relocation cases, does not apply to relocation issues that arise at the initial judgment for the dissolution of marriage.