When will a court order that the issue of primary residence be determined before a determination of final decision-making?

The Ontario Court of Appeal in Moreton v. Inthavixay, 2021 ONCA 501, stated there is no absolute rule or requirement that the issue of custody must be determined before the issue of relocation. Rather, the sequence depends on the circumstances of the case and the best interests of the children. In this matter, there is a temporary order in place for alternate week time and the matter was on the trial list for a determination of final decision-making. The father's move just prior to trial effectively blended the mobility issue with the decision-making and primary residence issue. I find that it is important though to specifically address the move under the rubric of a relocation issue. Doing so highlights the degree of control that the father has asserted throughout this litigation when he knew, or should have known, that his unilateral decisions were not authorized by law.