To add to Justice Jeffrey S. Sunshine's tribute to the late Justice Sondra Miller, it was her "best interests of the child" standard for child relocation cases that the New York Court of Appeals accepted in its landmark decision Tropea v. Tropea, 87 NY2d 727 (1996). I know because I was the appellate attorney who brought the successful leave application on behalf of the father in the companion case, Browner v. Kenward.