Child custody cases are some of the harder cases that practitioners face in the area of family law. Relocation cases are even more difficult and taxing on everybody involved. A relocation case involves a parent of a child or children desiring to move a distance away from the non-relocating parent. The Pennsylvania Child Custody Act has a specific section that addresses relocation cases. An interesting wrinkle involves a situation where the parents already live a significant distance apart and one parent seeks to move the child from where the child resides with the other parent to that parent's residence. This technically is not a "relocation." In 2014, in a case called D.K. v. S.P.K., 102 A.3d 467 (Pa. Super. 2014), the Pennsylvania Superior Court clarified that the requirements in the Child Custody Act surrounding relocation (such as notices and burdens, etc.) are not applicable when only the child would be moving.

The recent case of White v. Malecki, 296 A.3d 1210 (Pa. Super. 2023), addressed such a situation. In the White case, the parties moved to Germany with their child, the child's two half siblings, and paternal grandmother. According to the opinion: "a little over a week after arriving in Germany, the mother became gravely ill." The mother had four strokes and a few mini strokes, an aneurysm and a below the knee leg amputation. The mother was then transferred to Walter Reed Hospital in the United States to continue her treatment. Approximately eight months later she returned to Germany. Over the next several months, the parties' relationship deteriorated and the mother desired to return to the United States as she was dissatisfied with the level of care that she was receiving in Germany. According to the opinion, the mother had been unable to get fitted for a prostatic leg in Germany for over nine months and wanted to return to the Walter Reed Hospital to get fitted for the same. Thereafter, the  mother and the child and the maternal half sibling moved back to the United States. The father and the paternal half sibling and paternal grandmother remained in Germany. According to the opinion, "over the next two years, the parties operated without a formal custody order. The father primarily lived in Germany, but he communicated regularly with the child and visited him when he travelled back to the United States. During this time, the mother was primary caretaker."