Thursday, October 11, 2012

Is Florida the right jurisdiction to file in?

TRIAL COURT WAS CORRECT IN FINDING THAT IT HAD JURISDICTION TO MAKE A CUSTODY DETERMINATION UNDER THE UCCJEA WHERE NO OTHER STATE HAD JURISDICTION. 
The Father appealed from a final judgment of paternity which determined that the Florida courts had subject matter jurisdiction over the parties' custody dispute concerning the parties' eight-year-old daughter; granted custody of the child to the mother, ordered monthly child support; and placed the burden of visitation costs entirely on the father. With regard to the jurisdictional question, the District Court held:
1. "A Florida court has jurisdiction to make an initial child custody determination if Florida is the home state of the child on the date of the commencement of the proceeding. Home state is defined in relevant part as the state in which a child has lived with a parent or person acting as a parent for at least six consecutive months immediately before the commencement of a child custody proceeding."
2. "The UCCJEA gives jurisdictional priority to the child's home state. However, the UCCJEA grants an exception to the home state jurisdictional requirement when 'a court of another state does not have jurisdiction' Therefore, under the UCCJEA, even if Florida is not the child's home state, Florida may exercise subject matter jurisdiction over a child custody matter if another state does not have jurisdiction"

"On the date that the paternity action was commenced in this case, Florida was not the 'home state' of the child because the child had not lived in Florida for six consecutive months prior to the commencement of the paternity action…. However, no other state had jurisdiction since the mother and child had lived in several states in the six months prior to their arrival in Florida and the commencement of the paternity action."
4. "As a result, because no court of any other state would have had jurisdiction under section 61.514, the Florida trial court had jurisdiction to make an initial custody determination."
Hindle v. Fuith, 33 So.3d 782 (Fla. 5th DCA 2010)

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