Supreme Court of New Jersey
Jaime Taormina Bisbing v. Glenn R. Bisbing, III (077533) (Sussex County and Statewide)
August 8, 2017
Summary
The Appellate Division reversed the Family Part's orders allowing the custodial parent to relocate without a plenary hearing and remanded for such a hearing. The court required the lower court to first determine whether the marital settlement agreement was negotiated in bad faith, and if not, whether a substantial unanticipated change in circumstances justifies applying the Baures relocation test; otherwise a best‑interests analysis applies.