NJSBA Family Law Section

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  • 1.  UCCJEA & Palm Coast / Flagler County FL referral

    Posted 09-02-2016 04:16 PM
    As we know, under the UCCJEA a state must affirmatively relinquish jurisdiction - the new home state can't assume it.

    Parties have JOD from Florida. They both move to New Jersey. The Florida judgment is registered here. A new custody / parenting time order is issued in Somerset. Dad moves back to Florida. Kids go to see him for the summer and are now adamant that they don't want to return to NJ - saying they'll run away. Dad wants to file an OSC.

    Florida lost jurisdiction when the kids and the parents moved out, but there's no order relinquishing it.

    Can he file in Florida? If she files in Somerset (NJ), cross-apply to affirm NJ doesn't have jurisdiction? Or am I missing something?

    Anyone have a referral for Flagler County, Florida - hoping I can speak with counsel down there and see how FL would handle it.

    Thanks,

    <x-sigsep>

    David Perry Davis, Esq.
    ----------------------------------------------------
       www.FamilyLawNJ.pro
    ----------------------------------------------------
    112 West Franklin Avenue
    Pennington, NJ 08534
    Voice: 609-737-2222
    Fax:    609-737-3222

    </x-sigsep>


  • 2.  RE: UCCJEA & Palm Coast / Flagler County FL referral

    Posted 09-02-2016 04:24 PM

    If the parties consented to the entry of the new custody/parenting time Order issued in NJ or otherwise consented to NJ's jurisdiction by filing submissions/appearing in NJ, I believe jurisdiction will likely remain in NJ until both parties have left NJ.

    In addition, if the children have only been visiting Dad in Florida for the summer, the children likely have not been there for 6 months, so you would also have difficulty arguing Florida has(re) established itself as the children's home state.

    ------------------------------
    Blake W. Rush, Esq.
    Law Office of Blake W. Rush
    14 E. Main Street
    Clinton, NJ 08809
    (908) 713-9800 (PHONE)
    (908 713-9803 (FAX)



  • 3.  RE: UCCJEA & Palm Coast / Flagler County FL referral

    Posted 09-02-2016 04:46 PM
    Bill -
    <x-tab>        </x-tab>Thanks. I agree that Florida isn't the kids' home state, but we're not looking to establish jurisdiction, which I think is where the "home state" analysis comes into play.
    <x-tab>        </x-tab>I think it's a "simultaneous proceedings" issue / analysis if both states were entering custody / parenting time orders. Still looking for case / statute that discusses whether both parties leaving the State equates to a relinquishment of jurisdiction without an explicit order to that effect.

    Thanks again,


    David Perry Davis, Esq.
    ----------------------------------------------------
       www.FamilyLawNJ.pro
    ----------------------------------------------------
    112 West Franklin Avenue
    Pennington, NJ 08534
    Voice: 609-737-2222
    Fax:    609-737-3222




    § 2A:34-70. Simultaneous proceedings

    a. Except as otherwise provided in section 16 of this act [2A:34-68], a court of this State may not exercise its jurisdiction under this article if at the time of the commencement of the proceeding a proceeding concerning the custody of the child had been commenced in a court of another state having jurisdiction substantially in conformity with this act, unless the proceeding has been terminated or is stayed by the court of the other state because a court of this State is a more convenient forum under section 19 of this act [2A:34-71].

    b. Except as otherwise provided in section 16 of this act, a court of this State, before hearing a child custody proceeding, shall examine the court documents and other information supplied by the parties pursuant to section 21 of this act [2A:34-73]. If the court determines that a child custody proceeding was previously commenced in a court in another state having jurisdiction substantially in accordance with this act, the court of this State shall stay its proceeding and communicate with the court of the other state. If the court of the state having jurisdiction substantially in accordance with this act does not determine that the court of this State is a more appropriate forum, the court of this State shall dismiss the proceeding.

    c. In a proceeding to modify a child custody determination, a court of this State shall determine whether a proceeding to enforce the determination has been commenced in another state. If a proceeding to enforce a child custody determination has been commenced in another state, the court may: (1) stay the proceeding for modification pending the entry of an order of a court of the other state enforcing, staying, denying or dismissing the proceeding for enforcement; (2) enjoin the parties from continuing with the proceeding for enforcement; or (3) proceed with the modification under conditions it considers appropriate.


    At 04:24 PM 9/2/2016, you wrote:
    If the parties consented to the entry of the new custody/parenting time Order issued in NJ or otherwise consented to NJ's jurisdiction by filing...





  • 4.  RE: UCCJEA & Palm Coast / Flagler County FL referral

    Posted 09-02-2016 05:08 PM

    David:

    I think you are overlooking the significance that a custody/parenting time order has already been entered in NJ subsequent to the FL judgment of divorce.  

    If the NJ custody Order was entered through consent of both parties or as a result of motion practice where no one advanced the jurisdiction argument, I think both parties have waived the argument that NJ does not have proper jurisdiction at this point.

    For your argument to win, you essentially have to have the NJ custody Order declared null and void, and I don't see that happening based upon the facts you are describing.  The Father will appear to be forum-shopping in his attempt to have his forthcoming request for custody heard in FL because he resides there.

    ------------------------------
    Blake W. Rush, Esq.
    Law Office of Blake W. Rush
    14 E. Main Street
    Clinton, NJ 08809
    (908) 713-9800 (PHONE)
    (908) 713-9803 (FAX)
    www.blakerushlaw.com



  • 5.  RE: UCCJEA & Palm Coast / Flagler County FL referral

    Posted 09-02-2016 04:56 PM
    Home state jurisdiction only applies for initial custody orders. The only way NJ can lose jurisdiction is if both parents and the child cease to reside in NJ AND not OR the children no longer have a significant connection with NJ and there is no longer substantial evidence in the state concerning their care, protection, training and personal relationships. Read Griffith v. Tressel 394 NJ Super 128

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