Ronald A. MacKinnon, Plaintiff-Appellant v. Erika MacKinnon, Defendant-Respondent

Summary

The Supreme Court of New Jersey affirmed the trial court’s order allowing the custodial mother to relocate her minor daughter to Japan. The Court held that the Baures v. Lewis twelve‑factor test applies to international removal and that the trial court properly applied those factors, finding a good‑faith reason and no adverse effect on the child’s best interests. The Court also rejected the argument that Japan’s non‑participation in the Hague Convention bars relocation.