Mason Wayne Morris v. Jasmine Sharell Morris

Summary

The Louisiana Third Circuit Court of Appeal considered whether an Alabama divorce and custody judgment should be made executory in Louisiana. The court held that res judicata and law-of-the-case principles barred relitigation of Alabama's jurisdiction over the custody dispute, reversed the Louisiana trial court's judgment, and remanded for further proceedings.

Holdings

1. Res judicata applies to the Alabama judgment determining that Alabama had subject matter jurisdiction and bars Jasmine from raising the same jurisdictional issue in subsequent proceedings between the parties concerning Madeline's custody.
2. The law-of-the-case doctrine barred the trial court from reconsidering whether Alabama had exclusive, continuing jurisdiction over the custody dispute after the Third Circuit decided that issue in the prior appeal.
3. The Louisiana trial court erred in denying Mason's petition to make the Alabama divorce and custody decree executory because the final appellate determination of Alabama's exclusive, continuing jurisdiction could not be modified, revised, or reversed by the trial court.

Questions Presented

1. Whether the Alabama court's final judgment determining that Alabama had subject matter jurisdiction barred Jasmine under res judicata from relitigating jurisdiction in Louisiana.
2. Whether the prior Third Circuit decision holding that Alabama had exclusive, continuing custody jurisdiction constituted law of the case and barred reconsideration of that issue.
3. Whether the Louisiana trial court erred by denying Mason's petition to make the Alabama divorce and custody decree executory after the prior appellate decision became final.

Disposition

reversed_and_remanded