The case “Miller v. Miller” involves a dispute over the removal of a child from Massachusetts to Germany following the parents’ separation. The Supreme Judicial Court of Massachusetts addressed the standards applicable when a parent seeks to relocate a child without a formal custody order in place. The court emphasized the importance of determining whether the parenting arrangement more closely resembles sole or shared custody. This determination guides whether the “real advantage” standard or the “best interests” standard should be applied. The court ultimately upheld the trial judge’s decision, which found that the mother was the primary caregiver and that relocating the child to Germany was in the child’s best interest. The decision highlighted the significance of the child’s quality of life and the mother’s improved circumstances in Germany.