Bodne v. Bodne, 257 Ga. 445, 588 SE2d 728, has been the authority in Georgia regarding
parental relocation and modification of custody, since 2006. It sets forth that
relocation of a primary physical custodian alone cannot constitute a sufficient change in condition
to modify custody”. The court must consider the best interest of the child and the initial
custody award will not always control after any “new and material change in
circumstances” that...
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