In Re: Marriage of Condon is the leading authority on international move-away cases. In re Marriage of Condon (1998) 62 Cal.App.4th 533. Moving out of the country with a child will obviously have a dramatic effect on a child’s relationship with the non-moving parent. Therefore, there are special rules for international move-away cases.

The Court analyzed Burgess and LaMusga in its decision (see prior blog entitled Relocation (Move Away) with a Child), which are the leading cases on move away ases within the United States.

In Condon, the court granted a move-away with Mother to Australia, and four vacations per year with Father. The factors the trial court used in its analysis included Mother’s ability to financially support herself in Australia rather than be wholly dependent on Husband for support; the impact of the parties’ stressful relationship on the children; Mother’s extensive family in Australia; the children’s primary emotional...