In a Decision – A.J. v. R.J., (a "Reported Decision") >> the Court Held:
The Appellate Division determined that the result of Mother’s unauthorized move with the child was NOT an automatic Change in Custody.
The Appellate Court found that the trial court' Mother’s improper unilateral move with the child, did not automatically determine that custody must be changed.
The Appellate Division determined that although the trial court had authority to transfer custody to Father as a sanction against Mother, the Appellate Division determined that the trial court erred by changing custody without holding a best interests hearing or warning Mother that custody would be modified if she failed to return.