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Bisbing v. Bisbing

New Jersey Supreme Court
166 A.3d 1155 (2017)


Facts

When Jaime (plaintiff) and Glenn Bisbing (defendant) divorced, they agreed to split residential custody of their twin seven-year-olds. They agreed to live within a 15-minute drive of each other and that neither would relocate without the other’s consent. Four months later, Jaime announced she intended to marry someone in Utah and petitioned for permission to relocate with the children. The trial court applied New Jersey precedent, requiring that a primary residential parent need only show a good-faith reason to move and that moving will not harm the children’s best interests, and granted Jaime’s relocation request. But Glenn successfully appealed, arguing Jaime acted in bad faith and a best-interests standard should apply. Meanwhile, the trial court ordered the parties to live within 15 minutes of each other. Jaime moved back and petitioned for review of the decision.

Rule of Law

Issue

Holding and Reasoning (Patterson, J.)

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