C. D. v. R. C.

Syllabus

The plaintiff father, who had filed an application for child custody and visitation with respect to the parties' minor child, appealed from the trial court's judgment awarding the parties joint legal custody of the child, awarding the defendant mother primary physical custody of the child, and granting the defendant's request for permission to relocate from Connecticut to Virginia with the child. The plaintiff claimed, inter alia, that the court applied improper legal standards in considering the defendant's relocation request. Held: The trial court did not apply inapplicable law in favor of relocation but instead properly applied the best interest of the child standard in considering the defendant's relocation request, as the court repeatedly stated in its memo- randum of decision that its references to Ireland v. Ireland (246 Conn. 413), which is limited to postjudgment relocation cases, were offered in support of its consideration of the family unit as a whole and its factual findings as to the best interest determination. The trial court also did not assert different legal standards for relocation, as the plaintiff claimed, depending on whether the minor child's parents were married or unmarried, as the court's observations about the parties' circumstances and the fact that they had never been married to each other did not evidence the application of a more lenient standard to an unmarried parent seeking to relocate but, rather, could be read to distinguish postjudg- ment relocation cases and to pertain to the parties' relationship and its breakdown, especially in light of the court's repeated, proper recitation of the applicable legal standard in its decision. This court could not conclude that the trial court abused its discretion in permitting the defendant to relocate to Virginia with the minor child, as the court's finding that relocation was in the child's best interest was supported by detailed factual findings, including that the parties' circumstances i