custody and relocation factors in Pennsylvania

2017Further, with regard to the custody and relocation factors, we have stated as follows: “All of the factors listed in [S]ection 5328(a) are required to be considered by the trial court when entering a custody order.” J.R.M. v. J.E.A., 33 A.3d 647, 652 (Pa. Super. 2011) (emphasis in original).

2017Further, with regard to the custody and relocation factors, we have stated as follows: “All of the factors listed in [S]ection 5328(a) are required to be considered by the trial court when entering a custody order.” J.R.M. v. J.E.A., 33 A.3d 647, 652 (Pa. Super. 2011) (emphasis in original).

2021Mother cites S.J.S. v. M.J.S., 76 A.3d 541 (Pa. Super. 2013), for the proposition that the trial court may conduct a dual analysis of the custody and relocation factors when fashioning a custody order, rendering separate consideration of each individual factor unnecessary.

2020When a case involves custody and relocation issues, this Court has approved of “keeping both inquiries under a single umbrella of best interests of the children . . . .” Collins v. Collins, 897 A.2d 466, 473 (Pa. Super. 2006) (concluding that the trial court erred in awarding primary custody to a father despite the court’s conclusion that mother, who sought to relocate, was a better parent); see also S.J.S. v. M.J.S., 76 A.3d 541, 549-50 (Pa. Super. 2013) (concluding that the trial court did not err in engaging in a “dual analysis” of the custody and relocation factors and rejecting the mother

2022A.M.S., supra at 835 .

2022Id. at 833-34 (citing C.B., 65 A.3d at 952-53 ) (“To hold that the trial court may withhold its reasoning ____________________________________________ 3While there is some overlap between the custody and relocation factors, we note that not every factor is identical.

2023See C.R.F., 45 A.3d at 443 ; see also E.R., 129 A.3d at 527 . - 24 - J-A08001-23 Lastly, with her sixth issue, Mother additionally contends that the trial court erred in imposing an improper legal burden.

2022Therefore, we will not disturb them.22 See C.R.F., 45 A.3d at 443 ; see also E.R., 129 A.3d at 527 . ____________________________________________ 22 To the extent that Mother challenges the trial court’s inference that she would not comply with the terms of an order as to Father’s custody if relocation were granted, we conclude that the trial court made its credibility determination related to relocation factor 3 (23 Pa.C.S. § 5337(h)(3)).

2020Moreover, the trial court apparently dissociated its analyses of the custody and relocation factors rather than addressing both issues under a single umbrella.3 See Trial Ct. Op. at 7-8; Collins, 897 A.2d at 473 ; accord S.J.S., 76 A.3d at 550 .

2020When a case involves custody and relocation issues, this Court has approved of “keeping both inquiries under a single umbrella of best interests of the children . . . .” Collins v. Collins, 897 A.2d 466, 473 (Pa. Super. 2006) (concluding that the trial court erred in awarding primary custody to a father despite the court’s conclusion that mother, who sought to relocate, was a better parent); see also S.J.S. v. M.J.S., 76 A.3d 541, 549-50 (Pa. Super. 2013) (concluding that the trial court did not err in engaging in a “dual analysis” of the custody and relocation factors and rejecting the mother

2023See C.R.F., 45 A.3d at 443 ; see also E.R., 129 A.3d at 527 . - 24 - J-A08001-23 Lastly, with her sixth issue, Mother additionally contends that the trial court erred in imposing an improper legal burden.

2022Therefore, we will not disturb them.22 See C.R.F., 45 A.3d at 443 ; see also E.R., 129 A.3d at 527 . ____________________________________________ 22 To the extent that Mother challenges the trial court’s inference that she would not comply with the terms of an order as to Father’s custody if relocation were granted, we conclude that the trial court made its credibility determination related to relocation factor 3 (23 Pa.C.S. § 5337(h)(3)).

2023A.V., 87 A.3d at 822-23 .

2023See A.V., 87 A.3d at 820 ; see also W.C.F. v. M.G., 115 A.3d 323, 330 (Pa. Super. 2015) (stating that trial courts are not required to give weighted consideration to a parent’s prior role as primary caretaker when considering the custody and relocation factors) (citation omitted).

2023See A.V., 87 A.3d at 820 ; see also W.C.F. v. M.G., 115 A.3d 323, 330 (Pa. Super. 2015) (stating that trial courts are not required to give weighted consideration to a parent’s prior role as primary caretaker when considering the custody and relocation factors) (citation omitted).

2018Mother argues the court failed to discuss the possible effects of the custody arrangement, and in support cites E.A.L. v. L.J.W., 662 A. 2d 1109, 1117 (Pa. Super. 1995).