Four years after the divorce, the mother decided to move from Maryland to Arizona with a young daughter in the case of Braun v. Headley, 131 Md.App 588, 750 A.2d 624 (2000) decided by the Maryland Court of Special Appeals.

The mother had custody and the father had visitation every other weekend. The mother filed to modify visitation and the father filed to modify custody.

The court used a “best interest of the child” analysis and found in favor of the father.

The court said that the father had been actively involved in the child’s life and had consistently exercised his visitation rights. The court also said that relocation would disrupt substantial and meaningful contact with the parent left behind and that there were extended family members in Maryland who had a meaningful relationship with the child.