What is the test for disturbing the status quo?

Second, as I also indicated in Peet v. Zolob, supra, it seems to me that concerns about disturbing status quo have more force when that status quo is reasonably clear, and especially when it has been clearly defined by previous party agreement or a court order. Such arguments have less resonance in circumstances, such as the one before me, where there is a dispute as to how long the existing arrangement was intended to last, (e.g., extending beyond the summer or the transfer of ownership in the matrimonial home), and where continuation of the arrangement has been the subject of ongoing disagreement for much of its duration, without any prior court determination of what arrangement might be in the best interests of a child.

Third, as emphasized in authorities such as Holt v. Anderson, supra, not each and every proposed change, and corresponding alteration in the status quo, will be of equal magnitude and concern. Indeed, I am struck by Justice Lane’s principled rejection of a proposed “new” status quo that would have entailed “bouncing a small and bewildered child back and forth between parents”, with significant disruptions to an infant’s surroundings. In my view, such concerns apply in this case to the existing arrangements.