When a custody dispute arises after a initial award of custody has been made, does a parent who wishes to relocate with the child have a greater burden of proving parental relocation is necessary?

I also agree with the majority that when a relocation dispute arises after an initial award of custody has been made, the usual "changed circumstances" rule should apply. A child's welfare is not served by casual changes in caregiving arrangements, and the law abhors the endless relitigation of matters already determined. Hence, the parent who seeks a change in formal custody based on "changed circumstances" (including a parental relocation) bears the burden of persuading the court that in light of the new circumstances, an alteration of the existing award is in the child's "best interest." (Burchard v. Garay (1986) 42 Cal.3d 531, 536, 229 Cal.Rptr. 800, 724 P.2d 486.) Thus again, a parent who wishes to relocate with the child has no special burden of proving the move is "necessary."