Of all the potential issues that can arise in child custody cases, one of the most difficult and complicated to resolve is whether to permit the proposed relocation of the custodial parent. The relocation of the custodial parent necessarily impacts on the strength and quality of both parents' continued relationships with the child as well as fundamentally altering the child's environment, thus requiring substantial adjustments by all parties involved. Considering the opposing interests of the parties involved and the fact-intensive nature of the issues that must be addressed in each relocation case, it is easy to understand why they are rarely settled to everyone's satisfaction.