Fowler v. State, Department of Revenue, Child Support Services Division

Summary

The Alaska Supreme Court affirmed registration and enforcement of an Idaho child support order under the Uniform Interstate Family Support Act and the federal Full Faith and Credit for Child Support Orders Act. The court held that David Fowler received due process because he had notice of the default, the reasons for it, and a meaningful opportunity to be heard at a subsequent hearing, which he did not attend.

Holdings

1. The Idaho proceedings did not violate Fowler's procedural due process rights because, despite the rejection of his original answer, he received notice of the default and the reasons for it and had a meaningful opportunity to be heard at a subsequent hearing, which he chose not to attend.
2. The Alaska superior court properly registered the Idaho child support order because Fowler failed to show that the Idaho judgment was void for lack of due process.

Questions Presented

1. Whether the Idaho child support default judgment was void because the Idaho court rejected Fowler's answer for failure to pay a filing fee.
2. Whether the Idaho proceedings afforded Fowler due process when he received notice of the default, notice of the motion to strike his responsive pleadings, and a meaningful opportunity to attend a hearing.
3. Whether Alaska could register and enforce the Idaho child support order.

Disposition

affirmed