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9 Massachusetts opinions name it 2 courts 2007–2026 1 in the last five years
The cases below were cited by Massachusetts courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Yannas v. Frondistou-Yannasgreen2 sentences2012When assessing the best interests of the child under the Yannas analysis to determine “the extent to which moving or not moving will affect the emotional, physical, or developmental needs of the child,” id. at 711 , the Supreme Judicial Court has examined such factors as the financial, emotional, and social advantages associated with the proposed move; the availability of continued contact with both parents; the relative strengths of the local schools; and the home environment into which the children would be moving. 3 See Yannas, supra at 712 . 2012When assessing the best interests of the child under the Yannas analysis to determine “the extent to which moving or not moving will affect the emotional, physical, or developmental needs of the child,” id. at 711 , the Supreme Judicial Court has examined such factors as the financial, emotional, and social advantages associated with the proposed move; the availability of continued contact with both parents; the relative strengths of the local schools; and the home environment into which the children would be moving. 3 See Yannas, supra at 712 . | 3 | 6 |
Wakefield v. Hegartygreen2 sentences2010See Wakefield v. Hegarty, 67 Mass. App. Ct. 772, 775 (2006). 13 When a parent has sole custody of a child and seeks to relocate with the child outside the Commonwealth over the other, noncustodial parent’s objection, the analysis articulated in Yannas, supra at 710-712 , applies whether the parents are separated, divorced or were never married. 14 The Yannas analysis recognizes that “the best interests of a child are. . . interwoven with the well-being of the custodial parent,” and that moving may afford benefits to the custodial parent that, in turn, benefit the child. 2010See Wakefield v. Hegarty, 67 Mass. App. Ct. 772, 775 (2006). 13 When a parent has sole custody of a child and seeks to relocate with the child outside the Commonwealth over the other, noncustodial parent’s objection, the analysis articulated in Yannas, supra at 710-712 , applies whether the parents are separated, divorced or were never married. 14 The Yannas analysis recognizes that “the best interests of a child are. . . interwoven with the well-being of the custodial parent,” and that moving may afford benefits to the custodial parent that, in turn, benefit the child. | 3 | 3 |
Dickenson v. Cogswellgreen2 sentences2018The Yannas factors are: "(1) whether the quality of the [child's life] will be improved, including any improvement that 'may flow from an improvement in the quality of the custodial parent's life'; (2) any possible 'adverse effect of the elimination or curtailment of the child's association with the noncustodial parent'; (3) 'the extent to which moving or not moving will affect the [child's] emotional, physical, or developmental needs'; (4) the interests of both parents; and (5) the possibility of an alternative visitation schedule for the noncustodial parent." Murray v. Super , supra at 150 , 2018The Yannas factors are: "(1) whether the quality of the [child's life] will be improved, including any improvement that 'may flow from an improvement in the quality of the custodial parent's life'; (2) any possible 'adverse effect of the elimination or curtailment of the child's association with the noncustodial parent'; (3) 'the extent to which moving or not moving will affect the [child's] emotional, physical, or developmental needs'; (4) the interests of both parents; and (5) the possibility of an alternative visitation schedule for the noncustodial parent." Murray v. Super , supra at 150 , | 2 | 3 |
Prenaveau v. Prenaveaugreen2 sentences2018L. c. 208, § 30, does not apply, because there is a real advantage to the [w]ife in the proposed removal, and because the removal is consistent with [the child]'s best interests, it would bring about the same result if it did." See Prenaveau, 75 Mass. App. Ct. at 140 (court's conclusion that Mason was "the proper lens through which to repeated -- despite the stipulation's existence -- that "there is no court order" regarding custody. 16 Yannas itself involved an instance where there was no prior custody order; there, as here, the wife's removal petition was part of her divorce action. 2018L. c. 208, § 30, does not apply, because there is a real advantage to the [w]ife in the proposed removal, and because the removal is consistent with [the child]'s best interests, it would bring about the same result if it did." See Prenaveau, 75 Mass. App. Ct. at 140 (court's conclusion that Mason was "the proper lens through which to repeated -- despite the stipulation's existence -- that "there is no court order" regarding custody. 16 Yannas itself involved an instance where there was no prior custody order; there, as here, the wife's removal petition was part of her divorce action. | 1 | 1 |
Prenaveau v. Prenaveaugreen2 sentences2018See Prenaveau v. Prenaveau , 81 Mass. App. Ct. 479 , 486 (2012) ("the absence of evidence in support of findings, or the failure of the findings to support the judge's orders will constitute 'an abuse of discretion' and require reversal"). 2018See Prenaveau v. Prenaveau , 81 Mass. App. Ct. 479 , 486 (2012) ("the absence of evidence in support of findings, or the failure of the findings to support the judge's orders will constitute 'an abuse of discretion' and require reversal"). | 1 | 1 |
Woodside v. Woodsidegreen1 sentence2012See also Wakefield, 67 Mass. App. Ct. at 777-778 (similar analysis). 4 In Woodside, supra at 719-720 , we also looked at the proximity of family members who could assist in caretaking and the deleterious effects of increased travel. | 1 | 1 |
Cooper v. Coopergreen2 sentences2010Id. at 710 , quoting Cooper v. Cooper, 99 N.J. 42, 54 (1984). 2010Id. at 710 , quoting Cooper v. Cooper, 99 N.J. 42, 54 (1984). | 1 | 1 |
Williams v. Pitneygreen1 sentence2010See Williams v. Pitney, 409 Mass. 449, 455-456 (1991) (describing proper application of Yannas test). 3. | 1 | 1 |
Signorelli v. Albanogreen1 sentence2007See Signorelli v. Albano, 21 Mass. App. Ct. 939, 940 (1985) (remand required to consider Yannas factors, where judge gave insufficient “weight to the quality of life of the custodial parent by reason of the separations enforced on her, on her husband, and on her other child”); Rosenthal v. Maney, 51 Mass. App. Ct. at 268 , quoting from Yannas v. Frondistou-Yannas, 395 Mass. at 711 (no findings reflecting consideration of relationship of mother to child or “any improvement flowing from an improvement in the quality of the custodial parent’s life”). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Mason v. Coleman
green
2 sentences2012Accordingly, the husband argues, the proper standard for assessing the wife’s request to remove the child from the Commonwealth was that articulated by the Supreme Judicial Court in Mason v. Coleman, 447 Mass. 177 (2006) (Mason). 2012Accordingly, the husband argues, the proper standard for assessing the wife’s request to remove the child from the Commonwealth was that articulated by the Supreme Judicial Court in Mason v. Coleman, 447 Mass. 177 (2006) (Mason). | 2 | 2010–2012 |
Rosenthal v. Maney
green
2 sentences2010The standard governing the removal of children from the Commonwealth is set out in Yannas v. Frondistou-Yannas, 395 Mass. at 710-712 . 9 See Rosenthal v. Maney, 51 Mass. App. Ct. at 265-272 ; Wakefield v. Hegarty, 67 Mass. App. Ct. 772, 775-778 (2006). 2007See Signorelli v. Albano, 21 Mass. App. Ct. 939, 940 (1985) (remand required to consider Yannas factors, where judge gave insufficient “weight to the quality of life of the custodial parent by reason of the separations enforced on her, on her husband, and on her other child”); Rosenthal v. Maney, 51 Mass. App. Ct. at 268 , quoting from Yannas v. Frondistou-Yannas, 395 Mass. at 711 (no findings reflecting consideration of relationship of mother to child or “any improvement flowing from an improvement in the quality of the custodial parent’s life”). | 2 | 2007–2010 |
Hoegen v. Hoegen
green
2 sentences2026Because the weight assigned to each of these factors is a matter squarely within the judge's discretion, see Dickenson v. Cogswell, 66 Mass. App. Ct. 442, 452 (2006) ("balancing of the relevant factors in determining the child's best interests . . . involve[s] classic discretionary decision making by the trial judge"), and because the judge's decision was within "the range of reasonable alternatives," Hoegen, 89 Mass. App. Ct. at 9 , quoting L.L., 470 Mass. at 185 n.27, the judge did not abuse her discretion in concluding that removal would serve the child's best interests. 2. 2026Because the weight assigned to each of these factors is a matter squarely within the judge's discretion, see Dickenson v. Cogswell, 66 Mass. App. Ct. 442, 452 (2006) ("balancing of the relevant factors in determining the child's best interests . . . involve[s] classic discretionary decision making by the trial judge"), and because the judge's decision was within "the range of reasonable alternatives," Hoegen, 89 Mass. App. Ct. at 9 , quoting L.L., 470 Mass. at 185 n.27, the judge did not abuse her discretion in concluding that removal would serve the child's best interests. 2. | 1 | 2026–2026 |
L.L., a juvenile v. Commonwealth
green
2 sentences2026Because the weight assigned to each of these factors is a matter squarely within the judge's discretion, see Dickenson v. Cogswell, 66 Mass. App. Ct. 442, 452 (2006) ("balancing of the relevant factors in determining the child's best interests . . . involve[s] classic discretionary decision making by the trial judge"), and because the judge's decision was within "the range of reasonable alternatives," Hoegen, 89 Mass. App. Ct. at 9 , quoting L.L., 470 Mass. at 185 n.27, the judge did not abuse her discretion in concluding that removal would serve the child's best interests. 2. 2026Because the weight assigned to each of these factors is a matter squarely within the judge's discretion, see Dickenson v. Cogswell, 66 Mass. App. Ct. 442, 452 (2006) ("balancing of the relevant factors in determining the child's best interests . . . involve[s] classic discretionary decision making by the trial judge"), and because the judge's decision was within "the range of reasonable alternatives," Hoegen, 89 Mass. App. Ct. at 9 , quoting L.L., 470 Mass. at 185 n.27, the judge did not abuse her discretion in concluding that removal would serve the child's best interests. 2. | 1 | 2026–2026 |
Murray v. Super
green
2 sentences2018The Yannas factors are: "(1) whether the quality of the [child's life] will be improved, including any improvement that 'may flow from an improvement in the quality of the custodial parent's life'; (2) any possible 'adverse effect of the elimination or curtailment of the child's association with the noncustodial parent'; (3) 'the extent to which moving or not moving will affect the [child's] emotional, physical, or developmental needs'; (4) the interests of both parents; and (5) the possibility of an alternative visitation schedule for the noncustodial parent." Murray v. Super , supra at 150 , 2018The Yannas factors are: "(1) whether the quality of the [child's life] will be improved, including any improvement that 'may flow from an improvement in the quality of the custodial parent's life'; (2) any possible 'adverse effect of the elimination or curtailment of the child's association with the noncustodial parent'; (3) 'the extent to which moving or not moving will affect the [child's] emotional, physical, or developmental needs'; (4) the interests of both parents; and (5) the possibility of an alternative visitation schedule for the noncustodial parent." Murray v. Super , supra at 150 , | 1 | 2018–2018 |
Adoption of a Minor
green
1 sentence2010If this were a typical case, the relocation approach detailed in part 2, supra, would apply: any relocation by the mother to another State would require either the father’s consent or permission from a court utilizing a Yannas analysis. | 1 | 2010–2010 |
Catledge v. Evans
green
1 sentence2007Because the findings focus primarily on the negative effects of the move upon the son’s relationship with his father and sister, and because it is not apparent from the conclusions regarding the son’s best interests that the judge included within the best interests calculation appropriate “consideration of the quality of life of the custodial parent,” Pizzino v. Miller, 67 Mass. App. Ct. at 875 , we must vacate the judgment. c. | 1 | 2007–2007 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.