What is the test for a material change in circumstances in the context of a hearing where the threshold of material change has been met?

Gordon v. Goertz mandates that once the threshold of a material change in circumstances is met, the judge must embark on a fresh inquiry into what is in the best interests of the child “having regard to all the relevant circumstances relating to the child’s needs and the ability of the respective parents to satisfy them”. That sort of inquiry was not, and could not, have been undertaken in the context of the hearing that occurred. Counsel for J.L. expressly sought a broader hearing but was told in no uncertain terms “you’re not having a full hearing”. By requiring evidence to be presented by affidavit, by limiting the time available for presentation of the case and by unduly limiting the type of evidence to be presented, the judge deprived the parties - indeed, deprived J. - of a full and proper hearing designed to determine the child’s best interests in the circumstances which presented themselves.