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Army Lawyer


February, 1999

1999 Army Law. 16


Faculty, The Judge Advocate General's School


Uniform Interstate Family Support Act Long Arm Statute Interpreted

Among the major changes to child support enforcement under the Uniform Interstate Family Support Act 1 (UIFSA), are the broad long-arm jurisdiction provisions. 2 A court must have in personam jurisdiction over the obligor before it can order a support obligation. 3 If a state can meet one of the long-arm provisions under the UIFSA, it gains personal jurisdiction over a non-resident obligor and alleviates many of the cumbersome aspects of enforcing support interstate.

An interesting aspect of the UIFSA's long-arm provision is that it allows a state to assume personal jurisdiction based on the residence of the child in the state "as a result of the acts or directives of the non-resident obligor." 4 Only two cases have interpreted this particular long-arm provision. Both cases agree that this provision would be sufficient to establish jurisdiction and meet the Constitutional requirements of due process. The question becomes, what conduct is going to fall within the language of "acts or directives?"

In Windsor v. Windsor, 5 the Massachusetts Court of Appeals refused to find jurisdiction under this provision of the UIFSA. James Windsor and Beverly Windsor married at Otis Air Force Base in 1959. 6 The couple lived in several military locations, eventually ending up in Florida in 1975. Mrs. Windsor left Florida in June 1977, returning to Massachusetts where she delivered their fourth child in September 1977. 7 In 1995, she filed for divorce in Massachusetts ...
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