Brief Fact Summary. Wife brought a divorce decree in Washington where she formerly lived with her husband and child. Wyoming, the domicile of the husband, refused to honor the decree based on a lack of jurisdiction.
Synopsis of Rule of Law. The UIFSA, as adopted by both states requires a state to honor decrees by foreign states so long as the foreign state’s assumption of personal jurisdiction over appellee was consistent with that state’s general laws of jurisdiction as well as the Uniform Interstate Family Support Act.
Held. Washington’s assumption of personal jurisdiction over appellee was consistent with that state’s general laws of jurisdiction as well as the Uniform Interstate Family Support Act.
The UIFSA requires Wyoming courts to recognize and enforce a registered order if the issuing tribunal has jurisdiction. Appellee admits to residing with his wife and child in Washington while gainfully employed there. Pursuant to Washington law, a person not a citizen of the state can have jurisdiction exercised upon him if living in a marital relationship within the state notwithstanding subsequent departure from the state. Furthermore, the law is consistent with expressions found in both states’ codifications of the UIFSA. Therefore under the Full Faith and Credit Clause this Court must enforce a support order issued by a foreign court, because the court enjoyed personal jurisdiction over the obligor.
Discussion. The Court upholds the purpose of the UIFSA, which is designed to promote consistency and efficiency in multistate support cases.