Sometimes a trial judge will actually deny a mother permission to remove a child to a distant state, and in Young v. Forrest, unpublished, 16 VLW 118 (5/29/01), the Court of Appeals upheld such a decision from Chesterfield County.
The mother was trying to move to Alaska with her new husband and take her daughter -- the daughter of another man -- along. Several factors seemed to have influenced the Court of Appeals in finding the denial of relocation permission and transfer of custody to the natural father permissible. This mother had tried to move without telling the father, who had had for a long time a regular and satisfactory visitation arrangement and strong relationship with the child. Witnesses testified that the child often arrived for visitation dirty, messy and ravenous. The decision thus was not plainly wrong.