Nathan Cooper, Appellant v. Shannon Kalkwarf (cooper), Appellee — Hart, J., Dissenting

Summary

Justice Hart dissents from the majority's treatment of the circuit court's relocation decision, concluding that the circuit court carefully evaluated the evidence and that its factual findings were not clearly erroneous. She reasons that the court properly determined the parties did not have true joint custody, applied the relocation presumption, and found the move to be in the child's best interest. Chief Justice Kemp, concurring, questions whether relocation presumptions and threshold tests should be abandoned because they may artificially skew the analysis.