Massachusetts Divorce Custody Removal Of Children Modification

SUZANNE HOPE TAMMARO vs. KEVIN FRANCIScomplaints for modification. Although "a request for
O'BRIEN.modification of custody is distinct from a request to
No. 08-P-1762.relocate," Rosenthal v. Maney, supra at 261, the issues
APPEALS COURT OF MASSACHUSETTSare closely related.
76 Mass. App. Ct. 254; 921 N.E.2d 127Where removal is sought, a judge will be called upon to
October 8, 2009, Arguedconsider the children's well-being in light of any change
February 11, 2010, Decidedin visitation that might result if a move to a distant
Issues:location is permitted. As long as the complaint for
- Whether the Motion to dismiss the mother's complaintmodification provides notice to the opposing party of
for modification should be granted?the relief sought, it is an appropriate vehicle for
- Whether the judge failed to fully and fairly weigh therequesting removal of children from Massachusetts.
factors for removal?Whether the court failed to fully and fairly weigh the
The father argues that the judge (1) lacked thefactors for removal?
authority to permit removal of the children on aThe court held that "There was no error in the judge's
complaint for modification and thus should havefinding that the mother had established good, sincere
granted his motion to dismiss; and (2) failed to fully andreasons for wanting to remove to New Hampshire.
fairly weigh the factors for removal.That the mother's place of employment remains in
The court held that the father's motion to dismiss wasMassachusetts does not, in the circumstances, require
properly denied. Although the complaint here does nota different result."
specifically invoke G. L. c. 208, § 30, it states clearlyThe judge found specifically that the mother had
that the mother was requesting permission to removedemonstrated good, sincere reasons for the proposed
the children from the Commonwealth.  There is nomove to Derry. The mother's new employment
merit in the father's contention that even if theposition, which the judge found presented a "positive
mother's complaint was not fatally "defective," thechange" for the mother "professionally and financially,"
judge was bound to apply in the present case thehas a primary work site in Methuen, which is at least
standard applicable to a complaint for modification. Theninety minutes (or more) from Brockton. "Although it is
judge also did not err in admitting evidence ofnot inconceivable that the mother could find suitable
circumstances prior to the date of the parties' divorce.housing close in the Methuen MA area that meets all
Even in modification actions, a judge is not necessarilyof her housing criteria and is in her price range," the
precluded from considering matters prior to the earlierjudge specifically found that "she has made a sincere,
judgment.  Numerous decisions reflect that removaland good faith, albeit unsuccessful,  effort to do so.
cases in Massachusetts have been initiated through