Robertson v. Riplett

Summary

The Alaska Supreme Court held that an Alaska superior court lacked subject matter jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act to modify Ohio custody and visitation orders because Ohio retained exclusive, continuing jurisdiction and the father continued to reside there. The court also upheld the superior court’s order requiring the father to produce his income tax returns for purposes of enforcing child support obligations.

Holdings

1. The Alaska superior court lacked jurisdiction to modify the Ohio custody and visitation orders because the Ohio court had not declined exclusive, continuing jurisdiction or determined that Alaska was a more convenient forum, and Robertson still resided in Ohio.
2. The superior court properly required Robertson to submit his 2006 federal and Ohio state income tax returns because the Ohio support order was registered for enforcement and the returns were relevant to enforcing the child-support obligation.
3. Riplett was not required to provide her income tax information under Civil Rule 90.3(e)(2) because Robertson's request arose in an enforcement proceeding, not in a proceeding seeking modification of child support.

Questions Presented

1. Whether the Alaska superior court had subject matter jurisdiction under the UCCJEA to modify the Ohio custody and visitation orders.
2. Whether the Alaska superior court properly required Robertson to produce his 2006 federal and Ohio state income tax returns to aid enforcement of the Ohio child-support orders.
3. Whether Riplett was required to produce her income information under Alaska Civil Rule 90.3(e)(2).

Disposition

affirmed