Osgood

Thomas Landon (father or Tom) appeals from an order in favor of Julie Osgood (mother or Julie) that denied father’s motion to grant him physical custody of their son, Daniel James Landon (Daniel or Danny), which was based upon mother’s proposed relocation from California to Tennessee. Father argues the court incorrectly applied the “changed circumstances” (rather than the “best interest of the child”) standard to the proposed move, and that the error led to denial of his motion. For the reasons stated below, we shall conclude the trial court properly required father to establish that mother’s move would cause detriment to Daniel; father failed to establish such detriment; and substantial evidence supports the court’s order. Therefore, we shall affirm.

FACTUAL AND PROCEDURAL BACKGROUND

Father and mother were never married. Daniel was bom on July 30, 1998. On July 31, 2001, mother filed a petition to establish paternity and named father as respondent. In papers filed the following day, mother submitted a declaration of paternity wherein father admitted he was Daniel’s father.

Mother filed a request to enter default on September 12, 2001, and a default judgment was…