Prizzia v. Prizzia, No. 1343–10–2 (Virginia Court of Appeals, April 12, 2011): Hungary did not exercise jurisdiction over divorce and child custody under factual circumstances in substantial conformity with Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), and thus, trial court’s decision to decline to exercise jurisdiction to render initial custody determination did not comply with UCCJEA; Hungary did not have jurisdiction to make initial child custody determination as of date that wife filed action for divorce and custody in Hungary, in that child had not lived in Hungary for previous six months, and thus, Hungary was not child’s home state, and trial court had not conducted statutory analysis to determine whether Virginia was inconvenient forum and whether it was appropriate for Hungary to exercise jurisdiction.
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