Relocation cases may be filed either by the custodial parent seeking permission from the court to relocate or by the noncustodial parent in an attempt to block the proposed relocation. In resolving these disputes, jurisdictions often differ on the burden of proof involved and which party bears that burden. Generally, these jurisdictions all agree that a determination of the best interests of the child is essential; however, the states vary as to whose burden it is to establish whether a proposed relocation is in fact in the best interests of a child. Due to these differences, the outcome of a relocation case could fluctuate wildly depending on whether the burden is on the custodial or the noncustodial parent. In recent years, there has been a trend toward the application of a best-interests standard in resolving relocation cases, either by a court decision or by the enactment of a statute setting forth the applicable relocation standard. It should also be noted that the restrictive approach discussed in the 1996 article has been abandoned by all jurisdictions. See Tropea v. Tropea, 87 N.Y.2d 727, 665 N.E.2d 145, 642 N.Y.S.2d 575 (1996) (abrogating need to show "exceptional circumstances" before allowing relocation and adopting best-interests standard instead); Latimer v. Latimer, 2004 WL 1822753 (S.C. 2004) (abrogating presumption against relocation); cf. Ala. Code 30-3-169.4 (2004) (establishing rebuttable presumption that change in child’s residence is not in the child’s best interests).