What is the effect of a finding of an improper motive by a moving parent?

The issue of the effect of a finding of an improper motive by a moving parent arises from the oft-quoted passage in Gordon v. Goertz: “[t]he decision of the custodial parent to live and work where he or she chooses is likewise entitled to respect, barring an improper motive reflecting adversely on the custodial parenting ability” (at para. 48). This passage generally is referenced for the proposition that a respectful approach should be taken regarding a custodial parent’s decision about where to live and work. In a few trial level decisions, however, the passage has provided the basis for an express finding of an improper motive or an express finding of poor behaviour that has resulted in the “custodial” parent being denied permission to move.