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UCCJEA

Case Update (12 Jan 2023): Antonetti v. Westerhausen; Arizona defines “temporary absence” under definition of home state in UCCJEA

January 14, 2023

The Court of Appeals of Arizona denied Father's appeal where he argued that the trial court improperly assumed child custody jurisdiction under the UCCJEA over their dual Italian-U.S. son who was born in Tunisia in March 2018. In February 2020, the parties traveled to Italy for a vacation. … Read More about Case Update (12 Jan 2023): Antonetti v. Westerhausen; Arizona defines “temporary absence” under definition of home state in UCCJEA

Category iconhome state,  jurisdiction,  subject matter jurisdiction,  temporary absence,  UCCJEA

Case Update (5 Dec 2022): Olaide O. v. Oluseun O.; NY court assumes vacuum jurisdiction over child who has resided in Nigeria his whole life

December 29, 2022

This is a fascinating case, because a New York court concluded that, despite the child, F, having never resided in NY, the NY court had vacuum jurisdiction over the child. The child's two parents and 3 siblings all reside in the United States. They moved to the U.S. from Nigeria, but, due to a … Read More about Case Update (5 Dec 2022): Olaide O. v. Oluseun O.; NY court assumes vacuum jurisdiction over child who has resided in Nigeria his whole life

Category iconacting as a parent,  UCCJEA,  vacuum jurisdiction

Case Update (13 Oct 2022): In the Interest of AJT; subject matter jurisdiction over custody cannot be conferred by agreement, actions, or waiver

October 25, 2022

Joshua, father of AJT, filed a petition for divorce and custody in a Texas family court in July 2020. The parents participated in certain hearings and the court entered temporary orders regarding custody of AJT. Cypreana, the child's mother, then sought to have the custody matter dismissed, and the … Read More about Case Update (13 Oct 2022): In the Interest of AJT; subject matter jurisdiction over custody cannot be conferred by agreement, actions, or waiver

Category iconChild Custody,  custody,  dismiss,  subject matter jurisdiction,  UCCJEA

Case Update (29 June 2022): In re. Marriage of Randoy; 1 year in Canada was a temporary absence from California based on parents’ intent

July 12, 2022

The Randoys are married parents to one son born in Los Angeles in 2014. Marieke, a Canadian national, was having difficulty finding acting parts in LA, so she discussed, with Reed, taking their son to Canada, finding smaller TV roles there, booking several, and then returning to LA to audition "via … Read More about Case Update (29 June 2022): In re. Marriage of Randoy; 1 year in Canada was a temporary absence from California based on parents’ intent

Category iconhome state,  temporary absence,  UCCJEA

Case Update (7 June 2022): Dixon v. Smith; continuing exclusive jurisdiction declined for a more appropriate forum

June 27, 2022

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

Category icondecline jurisdiction,  inconvenient forum,  UCCJEA

Case Update (7 June 2022): Molina v. Pineda, Registration of Salvadoran custody order in U.S.

June 23, 2022

On June 7, 2022, the Maryland Court of Special Appeals, in an unreported opinion, affirmed the registration of a Salvadoran custody order that provided for a father's visitation. The parents secured a court order from El Salvador. The mother then relocated the child to Maryland, and the father … Read More about Case Update (7 June 2022): Molina v. Pineda, Registration of Salvadoran custody order in U.S.

Category iconregistration,  UCCJEA

Case Update (1 June 2022): Olajide v. Mockler; Motion for preliminary injunction denied; Nigerian father seeks UCCJEA be declared unconstitutional

June 16, 2022

On June 1, 2022, the U.S. District Court for the SD of Florida denied Mr. Olajide's request for an immediate hearing to obtain a preliminary injunction. From a review of Mr. Olajide's Complaint, it appears that he is a Nigerian national, residing in Florida (Miami-Dade). He is suing a variety of … Read More about Case Update (1 June 2022): Olajide v. Mockler; Motion for preliminary injunction denied; Nigerian father seeks UCCJEA be declared unconstitutional

Category iconabduction,  abduction prevention,  Child Abduction,  Child Custody,  constitutional,  custody,  due process,  UCCJEA

Case Update (24 May 2022): Makin v. Davis; Registration of UK custody order in Georgia

June 9, 2022

The Court of Appeals of Georgia reversed a trial court that had refused to register and enforce a UK custody order in Georgia. The opinion outlines some of the arguments both parents made. The arguments, themselves, are quite confusing and miss the mark. The court distilled the case as a simple … Read More about Case Update (24 May 2022): Makin v. Davis; Registration of UK custody order in Georgia

Category icondomesticate,  enforcement,  registration,  UCCJEA,  United Kingdom

Case Update (19 May 2022): VK v. KK; temporary absence and UCCJEA custody jurisdiction

June 2, 2022

The parents are Indian nationals that lived in Cleveland, Ohio. Their child was born in Cleveland, and is a U.S. citizen. On or about February 21, 2018, the family traveled to India for a family wedding. While there, the parents separated so they could each visit with their own family members, … Read More about Case Update (19 May 2022): VK v. KK; temporary absence and UCCJEA custody jurisdiction

Category iconhome state,  temporary absence,  UCCJEA,  unjustifiable conduct

Case Update (18 Jan 2022): NY ex rel. BE; Writ of Habeas Corpus; Habitual Residence

March 15, 2022

On January 18, 2022, the Supreme Court of Kings County, NY denied a Father's petition for emergency jurisdiction to return his son to England, and his request for an opinion that England was the child's habitual residence. The parties are parents to one child, adopted in 2013. The family … Read More about Case Update (18 Jan 2022): NY ex rel. BE; Writ of Habeas Corpus; Habitual Residence

Category iconabduction,  Child Abduction,  emergency jurisdiction,  habeas corpus,  Habitual Residence,  Hague Abduction Convention,  temporary emergency jurisdiction,  UCCJEA

Case Update (28 January 2022): In re. BV; UCCJEA jurisdiction when there is no home state

February 15, 2022

The minor child, BV, was placed with a foster parent by the LA County Department of Children and Family Services (DCFS) after allegations that her parents abused her. The minor child and her mother traveled to California, as undocumented immigrants, approximately 2-3 months prior to DCFS removed … Read More about Case Update (28 January 2022): In re. BV; UCCJEA jurisdiction when there is no home state

Category iconabuse,  child abuse,  home state,  UCCJEA,  unjustifiable conduct

Case Update (13 Jan 2022): Senay Akin v. Nedim Suljevic; returning a wrongfully retained child – Hague Abduction and UCCJEA paths

January 27, 2022

The Supreme Court of NH affirmed the registration and enforcement of a Turkish custody order, returning the parties' child to the mother. The parties are parents to one daughter, born in Turkey in 2011. She continuously lived in Turkey until 2019. She attended school and received medical care in … Read More about Case Update (13 Jan 2022): Senay Akin v. Nedim Suljevic; returning a wrongfully retained child – Hague Abduction and UCCJEA paths

Category iconabduction,  Child Abduction,  enforcement,  Hague Abduction Convention,  registration,  UCCJEA

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