In the case of Haas v. Puchalski, Michele Puchalski Haas filed for divorce from Raymond J. Puchalski, Jr. in the Probate Court of Franklin County, Massachusetts. The divorce was granted on the grounds of cruel and abusive treatment, and Michele was awarded custody of their son, Joshua, with visitation rights for Raymond. The court prohibited Michele from removing Joshua from the Commonwealth without Raymond’s consent. Later, Raymond sought to modify the custody arrangement, arguing that Michele’s removal of Joshua from the state without his consent constituted a change in circumstances. However, the court found that Michele’s actions did not warrant a change in custody, and the original custody arrangement was upheld.