Grumme v. Grumme

Summary

The Mississippi Supreme Court considered whether a Mississippi chancery court had jurisdiction under the Uniform Interstate Family Support Act to register, enforce, and modify a child-support order issued by the Superior Court of Guam. The court held that the foreign order could be registered and that Mississippi had jurisdiction to modify it because the parties and child no longer resided in Guam, the petitioner was a nonresident of Mississippi, and the respondent resided in Mississippi. The court reversed the dismissal for lack of jurisdiction and remanded.

Holdings

1. Mississippi's registering tribunal had jurisdiction to register and enforce the Guam child-support order, and Darren's objection did not establish any of the statutory defenses to registration or enforcement.
2. The Jackson County Chancery Court had jurisdiction under UIFSA to modify the Guam support order because neither parent nor the child resided in Guam, Claire was a nonresident of Mississippi, and Darren was subject to personal jurisdiction in Mississippi.
3. The parties' agreement concerning jurisdiction did not require dismissal of the UIFSA petition because the statutory requirements independently established Mississippi jurisdiction.

Questions Presented

1. Whether the Jackson County Chancery Court had jurisdiction under UIFSA to register and enforce the Guam child-support order when none of the parties or the child resided in Guam and Darren resided in Mississippi.
2. Whether the Jackson County Chancery Court had jurisdiction under UIFSA to modify the Guam child-support order when the petitioner was a nonresident of Mississippi and the respondent was subject to personal jurisdiction in Mississippi.
3. Whether the parties' agreement regarding jurisdiction and Nelson v. Halley required dismissal of Claire's UIFSA petition.

Disposition

reversed_and_remanded