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.

At the time, a parent seeking to relocate with their child faced a presumption against such relocation. My leave application was based mainly on the argument that the Appellate Division, Second Department, in a decision authored by Justice Miller, applied a new standard, the "best interests of the child," ignoring the presumption against relocation and minimizing the interests of the aggrieved parent.