OCS/Pappas v. O'Brien
Supreme Court of Vermont
67 A.3d 916 (Vt. 2013)
After divorcing in California, Glenn Pappas (plaintiff) and Nan O'Brien (defendant) relocated separately, with O'Brien registering the California custody decree in Georgia and later increasing support there; when their son P.P. moved in with Pappas in Oklahoma, Pappas obtained an Oklahoma order awarding him custody, relieving his support obligation, and ordering O'Brien to pay him support, followed by an administrative order awarding retroactive support once P.P. returned to O'Brien in Georgia. After O'Brien later moved to Vermont, Pappas, through Vermont's Office of Child Support (OCS), registered the Oklahoma support order there under the Uniform Interstate Family Support Act (UIFSA); O'Brien challenged the registration and separately tried to register the Georgia order and stay the Vermont proceedings, and the Vermont court granted OCS's motion to dismiss O'Brien's separate action, prompting consolidated appeals.
Whether a party who voluntarily initiates a UIFSA proceeding in a state to enforce a child-support order thereby waives any objection to that state's personal jurisdiction over him for related matters in the same proceeding.