Carita L. Baures, Plaintiff-Appellant v. Steven R. Lewis, Defendant-Respondent

Summary

The Supreme Court of New Jersey reversed the trial court's denial of Baures' request to relocate with her son and remanded for further proceedings. The Court clarified that a custodial parent must show a good‑faith reason for moving and that the move will not be inimical to the child's best interests, with visitation considered part of that overall analysis. The Court found Baures had met the good‑faith requirement but had not produced sufficient evidence of comparable special‑education services in Wisconsin, and it held the trial court erred in its assessment of Lewis' employment prospects.