SANDRA COSTA VS. PAULO A. COSTA A-2078-13T4A parent's relocation to another country, while normally a change of circumstances warranting modification of that parent's physical custody, does not necessarily constitute a change of circumstances warranting modification of joint legal custody. Modern communications can enable the distant parent to remain a joint decision-maker in the major decisions regarding the children's welfare.
A change in joint legal custody is not justified by difficulties in renewing the children's passports, where the foreign parent consents to a court order authorizing the domestic parent to obtain a passport for the children regardless of the custodial arrangements, and authorizing the minor to travel. See 22 C.F.R. § 51.28(a)(3)(ii)(E) (2014).