California, United States of America
The following excerpt is from Marriage of Whealon, In re, 53 Cal.App.4th 132, 61 Cal.Rptr.2d 559 (Cal. App. 1997):
In the wake of that instruction, this court, in Brody v. Kroll (1996) 45 Cal.App.4th 1732, 53 Cal.Rptr.2d 280, had recent occasion to hold, in a case where the parties had "actual" joint physical custody of the child, that a family law court should reconsider the basic custody arrangement when one of the parents moved away from the area.
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