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Marriage of M. CA4/1
Raphael M. (Father) appeals an April 2016 postjudgment order allowing Monica M. (Mother) to move to Georgia with the parties' 11-year-old son, K.M. On appeal, Father claims the move-away order must be reversed because the trial court applied the incorrect legal standard. He also challenges the sufficiency of the evidence supporting the court's finding of child abuse. We conclude substantial evidence supports the abuse finding. However, the court did not apply the correct legal standard in granting Mother's move-away request. We therefore reverse the April 2016 and June 2016 move-away rulings and remand for the trial court to make a determination as to move-away based on the correct legal standard.

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