Gordon v Goertz is a 1996 Supreme Court of Canada decision dealing with issues surrounding parental relocation.

Instead of having a presumption in favour of the custodial parent, the court held that a move would only be allowed if it was in the best interests of the child.

The court rejected putting an onus on either party because it thought that the best interests of the child would best be determined if there were no starting presumptions.

[7] In Gordon, the Supreme Court of Canada cleared up any confusion about whether there should be a presumption in favour of the moving parent.

The court set out the law as follows: the party seeking to vary the custody agreement would first have to show that the move would cause a material change in the circumstances of the child.