The parties and their 2 children are Canadian citizens who migrated to the United States in 2014. They divorced in Delaware in 2016, and in 2018, after a full merits trial, the Delaware Family Court permitted the mother to relocate the children to Canada. In February 2021, the father filed a suit in … Read More about Case Update (7 June 2022): Dixon v. Smith; continuing exclusive jurisdiction declined for a more appropriate forum
Case Update (2021): In re Marriage of Pitcairn; inconvenient forum, divorce petition dismissed
On June 30, 2021, the Court of Appeals of Iowa affirmed the trial court's dismissal of Ms. Pitcairn's petition for marriage dissolution on the basis of forum non conveniens. Ms. Pitcairn and Mr. Renaud married in France in 2005, lived most of their marriage in France, Mr. Renaud is French and Ms. … Read More about Case Update (2021): In re Marriage of Pitcairn; inconvenient forum, divorce petition dismissed
Case Update (2021): Pokrovskaya v. Van Genderen; UCCJEA inconvenient forum
Mother and Father divorced in Wyoming in 2016. They are parents to one child. The Wyoming Court awarded Father custody, with Mother having 10 days of visitation each month. The Mother resided, and continues to reside, in Russia. In 2018, the Father and child moved to Russia, spent the 2019 … Read More about Case Update (2021): Pokrovskaya v. Van Genderen; UCCJEA inconvenient forum
Case Update (2021): In Re Marriage of Margain; UCCJEA and a foreign country’s declination of jurisdiction
I will no doubt be using this case, In Re Marriage of Margain, as an exam question for my law students. Mother and Father married in Mexico in 2007, and had their child in California in 2008. In 2010, and for at least a year and a half, the Mother and child moved to and lived in Mexico. The … Read More about Case Update (2021): In Re Marriage of Margain; UCCJEA and a foreign country’s declination of jurisdiction
Case Update (2021): Koivu v. Koivu; inconvenient forum under UCCJEA
In the unreported opinion of Koivu v. Koivu, the Minnesota Court of Appeals addressed the issue of whether Minnesota should decline jurisdiction over the Koivu children's custody because it was an inconvenient forum as compared to Finland. The couple lived in Minnesota for the better part of … Read More about Case Update (2021): Koivu v. Koivu; inconvenient forum under UCCJEA