In the case of Rosenthal v. Maney, the mother, Amy P. Rawstron Rosenthal, sought to relocate with her child to Rhode Island, where she worked and her new husband resided. The father, Paul S. Maney, opposed the move, arguing it was not in the child’s best interest and sought custody modification. The trial court denied the mother’s request and transferred custody to the father. However, the Appeals Court reversed this decision, emphasizing that the father’s request for custody modification must be based on a substantial change in circumstances unrelated to the move. The court highlighted that the mother had a sincere reason for relocating, which provided a real advantage. The court also outlined factors to consider in determining the child’s best interests, including the child’s quality of life improvement, the impact on the child’s relationship with the noncustodial parent, and the child’s emotional and developmental needs.