Ghana was a more appropriate forum in which to litigate custody of parties’ child, and thus dismissal of mother’s later-filed action in Maryland, in favor of father’s prior-filed action in Ghana, was warranted, even though Maryland court had home state jurisdiction over child pursuant to Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA); although child had been in Ghana less than 28 days at time that father filed action in Ghana, child had been born in Ghana, had resided in Maryland from age seven to age 14, and, in the two years since the filing of father’s action, had lived continuously in Ghana and attended high school there.
Laura Morgan is a Family Law Consultant. Laura is available for consultation, brief writing and research on family law issues throughout the country. She can be reached through her website. www.famlawconsult.com