In re Marriage of Haugh
Court of Appeal of California
225 Cal. App. 4th 963 (Cal. Ct. App. 2014)
Christopher Haugh (plaintiff) and Gabriela Haugh (defendant) divorced in California, where the court ordered Christopher to pay $700 a month in child support for their son. Afterward, Gabriela and the child moved to Texas and Christopher moved to Nevada. With no party left in California, Christopher filed a petition there to reduce his support payments, and neither he nor Gabriela ever consented in writing to California retaining jurisdiction. The trial court granted his petition anyway. The San Diego Department of Child Support Services intervened and appealed on jurisdictional grounds under the Uniform Interstate Family Support Act (UIFSA) and the federal Full Faith and Credit for Child Support Orders Act (FFCCSOA).
Whether, under UIFSA and the FFCCSOA, the state that issued a child-support order retains jurisdiction to modify it once all relevant parties have permanently left that state and none has consented in writing to its continuing jurisdiction.