Child Custody, Visitation & Relocation

Parental Grandmother Is Not The Psychological Parent And Had No Standing To Oppose Child Relocation

In the family law, child relocation of M.O. v. N.H., App. Div. 20-2-8597, the plaintiff, the paternal grandmother of 7-year-old J.O., appealed the court’s grant of the motion of N.H., the child’s mother, to relocate with the child to South Carolina. The father, Z.O., did not oppose the motion. The panel affirmed. Applying the standards in V.C. v. M.J.B., the panel found there was no evidence showing that the grandmother was a “psychological parent;” even if the child had lived in the grandmother’s household four days per week during the first six months of his life, during the ensuing years he lived with his mother; there was no evidence that the grandmother assumed the obligations of parenthood by taking significant responsibility for the child’s care, education and development, including contributing to his support without expectation of financial compensation; and the grandmother did not set forth any facts in her certification establishing that the child was in a bonded, dependent relationship with her that was parental in nature. Accordingly, the panel held that the court was not required to conduct a plenary hearing and that the grandmother had no standing to Oppose Child Relocation.

Reference: Case & Analysis, New Jersey Law Journal 221 N.J.L.J. 1918 (December 14, 2015)

Filed Under: Child Relocation, Paternal Grandparent; No Standing

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