Kulko v. Superior Court

Sharon Kulko Horn (plaintiff) and Ezra Kulko (defendant), New York residents, married briefly in California in 1959 and then lived together in New York for 13 years before separating; Horn later moved to California and signed a New York separation agreement providing the children would live with her in California only during vacations while residing with Kulko in New York during the school year, with modest annual child support. Horn obtained a Haitian divorce incorporating that agreement. Over the following years, both children successively asked to live with Horn full-time; Kulko bought each a one-way plane ticket to California at their own request. Horn then moved a California court to recognize the Haitian decree, obtain full custody, and increase support; Kulko challenged personal jurisdiction, but the court found jurisdiction based solely on his act of sending his daughter to California, and Kulko appealed.