In the five years after her divorce became final, a former wife moved to and from Florida multiple times.  The former husband had primary parenting responsibility, but his ex-wife attempting to modify their time-sharing agreement by alleging her final move back to Florida was a “substantial change in circumstances” that necessitated her gaining increased time with her children.  The family court judge agreed and modified the time-sharing agreement, but was reversed by a northern Florida appeals court.  The appellate court found that the ex-wife’s move back to Florida, with nothing more, was insufficient to constitute a change in circumstances.

The case was Bryan v. Wheels, and the appellate court opinion can be read here.