Ross v. Ross, 2019 UT App 104 (June 13, 2019)

Intending to move from Salt Lake County to Uintah County with her two children, the appellee filed a notice of relocation pursuant to Utah Code § 30-3-37.  After a two-day evidentiary hearing, the district court granted the relocation request, which resulted in a change to the physical custody arrangement and the primary physical custodian.  Analyzing the interplay between the relocation statute and Rule 106, the court of appeals reversed and held that a party seeking to relocate cannot simply file the statutory notice, but instead must file a petition to modify if the relocation will effectuate a change in custody in favor of the relocating party.