Tl v. Jl, 950 N.E.2d 779

Mother (T.L.) filed a notice of intent to relocate with two sons from Montgomery County, Indiana to Tullahoma, Tennessee; Father objected.
The dissolution decree granted Mother primary physical custody with joint legal custody; Father had substantial weekday and weekend involvement and supported the children, including sports duties.
Mother proposed relocation to be closer to her ill grandmother, to access family support, and to pursue nursing education with family funding; she proposed a plan for Father’s caretaking time if relocation occurred.
The trial court granted an injunction preventing relocation during merits proceedings and later found that the relocation was not in the children's best interests, ruling in favor of Father.
The appellate court reviewed under Indiana relocation statute framework, affirmed in part and reversed in part findings of fact but ultimately affirmed denial of relocation, concluding good faith reasons were shown but best interests favored denial.
Key holding: relocation was in good faith with legitimate reasons, but not in the children’s best interests; judgment denying relocation was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mother's relocation was proposed in good faith and for legitimate reasons	Mother acted in good faith for legitimate reasons (family proximity, financial relief, education).	Trial court erred by finding lack of good faith; evidence supported relocation for personal reasons.	Relocation was in good faith and for legitimate reasons.
Whether relocation is in the children's best interests	Relocation would benefit children through improved education and family support; long-term benefits outweigh disruption.	Relocation would substantially disrupt Father’s relationship and child stability, harming best interests.	Relocation not in the children's best interests; denial affirmed.

Baxendale v. Raich, 878 N.E.2d 1252 (Ind. Ct. App. 2008) (two-prong framework: good faith/legitimate reason and best interests)
In re Paternity of X.A.S., 928 N.E.2d 222 (Ind. Ct. App. 2010) (move to California under spouse's Navy service; court weighed best interests)
Swadner v. Swadner, 897 N.E.2d 966 (Ind. Ct. App. 2008) (good faith relocation when moving to reside with family for care/finances)
Rogers v. Rogers, 876 N.E.2d 1121 (Ind. Ct. App. 2007) (relocation to Texas with better employment and family ties supported)
In re Marriage of Best, 941 N.E.2d 499 (Ind. 2011) (deference to trial judge in family law; credibility and best interests given weight)
M.S. v. C.S., 938 N.E.2d 278 (Ind. Ct. App. 2010) (standard of review for custody-related decisions; deference to trial court)