When A Parent Wants To Move: Understanding Domingues V. Johnson And Maryland Relocation Law

Custody battles are tough to begin with — but things get even more complicated when one parent wants to move away. Whether it’s for a new job, to be closer to family, or just to start over, relocating can have a big impact on a child’s connection with both parents. In Maryland, one of the key cases that sheds light on how courts handle these situations is Domingues v. Johnson. It’s a case that lays out how judges try to strike a fair balance between a parent’s reasons for moving and what’s truly best for the child.

Background of the case 

In Domingues v. Johnson, the parents shared a custody arrangement for their young children. When the mother announced her intention to relocate out of Maryland, the father objected and sought a change in custody. He argued that the move would significantly disrupt his time with the children and damage his relationship with them.

The trial court agreed and transferred custody to the father. The mother appealed, and the case ultimately landed before Maryland’s highest court: the Court of Appeals.

The central issue was: Is a parent’s relocation, by itself, enough to justify changing custody?

Maryland’s appellate courts had not yet created a clear framework for relocation cases, so Domingues became the foundation for how judges analyze these disputes.

The appeal 

The Court of Appeals made several critical rulings that continue to shape relocation cases today:

• Relocation may be a “material change in circumstances” – The court explained that a parent’s move can be significant enough to reopen custody, but it is not automatically a reason to transfer custody to the other parent. The impact must be meaningful and tied to the child’s welfare, not just the parent’s preferences.

• The court must focus on the child’s future best interests – Unlike some situations where judges look for past harm, relocation cases require evaluating what will happen going forward. How will the move affect the child’s emotional well-being? What opportunities or disruptions does the new location present? How feasible is long-distance parenting for the non-relocating parent?

• No bright-line rules. Every case is fact-specific — The court stressed that relocation cases are highly individualized. Judges must consider the unique dynamics of the family. Elements such as parenting history, communication patterns, financial stability, school continuity, and the child’s social environment are paramount.

Why this case still matters today 

More than 30 years later, Domingues v. Johnson remains the anchor for Maryland relocation law. It established the guiding principle that custody decisions must always hinge on what best serves the child, not punishing the parent for moving and not on automatically privileging stability over mobility.

The case also paved the way for later decisions, which reinforced the need for detailed evidence and careful judicial analysis when parents disagree about moving a child to a new state.

Talk to a Bel Air, Maryland, Divorce Lawyer Today 

Schlaich & Thompson, Chartered, represents the interests of Maryland residents during their divorce. Call our Bel Air family lawyers today to schedule an appointment, and we can begin discussing your next steps right away.