Revised Code of Washington
Wash. Rev. Code § 26.09.420 (2026)
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✓ current as of May 2026
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When entering or modifying a court order, the court has the authority to allow or not allow a person to relocate the child.
[ 2000 c 21 s 4.]
Notes:
Intent—Captions not law—2000 c 21: See notes following RCW 26.09.405.
Notes of Decisions
Cited in 14
cases (1 in the last 5 years), 2002–2021 · leading case: In Re Marriage of Fahey, 262 P.3d 128 (Wash. Ct. App. 2011).
In Re Marriage of Fahey, 262 P.3d 128 (Wash. Ct. App. 2011). “The objecting person may rebut the presumption by a showing that, with regard to the child and relocating person, the detrimental effects of relocating outweigh the benefits.”
In re the Marriage of Fahey, 164 Wash. App. 42 (Wash. Ct. App. 2011). “The objecting person may rebut the presumption by a showing that with regard to the child and relocating person, the detrimental effects of relocating outweigh the benefits.”
In re the Marriage of Grigsby, 57 P.3d 1166 (Wash. Ct. App. 2002). “” RCW 26.09.420. In enacting these provisions, the Legislature specifically stated that its intent was to supersede the Supreme Court’s *7 decisions in In re Marriage of Littlefield and In re Marriage of Pape.”
Osborne v. Osborne, 79 P.3d 465 (Wash. Ct. App. 2003). “RCW 26.09.420; In re Marriage of Grigsby, 112 Wn.”
In Re Marriage of Grigsby, 57 P.3d 1166 (Wash. Ct. App. 2002). “" RCW 26.09.420. In enacting these provisions, the Legislature specifically stated that its intent was to supersede the Supreme Court's decisions in In re Marriage of Littlefield and In re Marriage of Pape.”
In Re Custody of Osborne, 79 P.3d 465 (Wash. Ct. App. 2003). “RCW 26.09.420; In re Marriage of Grigsby, 112 Wash.”
Ramirez v. Holland, 122 Wash. App. 324 (Wash. Ct. App. 2004). “This presumption may be rebutted by a showing that the detrimental effect of relocation will *329 outweigh the benefits of relocation to the child and the relocating person, based on 11 factors.”
In Re Parentage of RFR, 93 P.3d 951 (Wash. Ct. App. 2004). “This presumption may be rebutted by a showing that the detrimental effect of relocation will outweigh the benefits of relocation to the child and the relocating person, based on 11 factors.”
In re the Marriage of Horner, 58 P.3d 317 (Wash. Ct. App. 2002). “RCW 26.09.420. RCW 26.09.430. RCW 26.09.480(1).”
Marriage of Horner, 58 P.3d 317 (Wash. Ct. App. 2002). “[16] CP at 52. [17] CP at 62. [18] CP at 59. [19] CP at 59-60.”
In Re the Marriage of Wehr, 267 P.3d 1045 (Wash. Ct. App. 2011). “RCW 26.09.420; In re Parentage of R.F.R., 122 Wn.”
In re the Marriage of: Jamie D. Miksch & Mindy R. Miksch (Wash. Ct. App. 2018). “RCW 26.09.420; In re Parentage of R.F.R., 122 Wn.”
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