Appellate decision · New York · Parental relocation
New York appellate court affirms denial of proposed move to Florida
The Fourth Department applied the established Tropea factors and found a sound and substantial basis for denying the proposed relocation.
CaseMatter of Villani v Wendig, 246 AD3d 1402CourtAppellate Division, Fourth DepartmentDecision date and statusFebruary 11, 2026 · decided
Published November 3, 2026 · Reviewed by David Martino
The Appellate Division affirmed denial of a mother’s request to relocate her daughter to Florida. Applying Tropea, it considered the record on the child’s connections, education, sibling relationship and future contact with her father. The moving parent bore the burden by a preponderance. The court held that even assuming error in excluding evidence of alleged past abuse, any error was harmless on this record. This fact-specific ruling does not make a single factor decisive.