Snow v. Snow
Oregon Court of Appeals
74 P.3d 1137 (2003)
Following the Snows' 1995 North Dakota divorce granting Mr. Snow custody of their son S, the child was primarily raised in Oregon by his paternal grandmother (plaintiff) after Mr. Snow moved there; after growing suspicious of abuse, Grandmother moved S to England and then petitioned for full custody in Oregon, arguing four years of Oregon residence gave that state jurisdiction, while Mr. Snow (defendant) argued North Dakota retained jurisdiction since Ms. Snow still lived there and the original custody decree issued there.
Whether a request to change or replace a previous custody order concerning the same child is treated as a modification request, rather than an initial custody action, for jurisdictional purposes under the Uniform Child Custody Jurisdiction and Enforcement Act.