B.D. v. D.A.B.

CourtNew Jersey Superior Court Appellate Division
DecidedSeptember 18, 2024
DocketA-1062-23
StatusUnpublished

This text of B.D. v. D.A.B. (B.D. v. D.A.B.) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
B.D. v. D.A.B., (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-1062-23

B.D.,1

Plaintiff-Appellant,

v.

D.A.B.,

Defendant-Respondent. _________________________

Submitted September 12, 2024 – Decided September 18, 2024

Before Judges Sabatino and Berdote Byrne.

On appeal from the Superior Court of New Jersey, Chancery Division, Family Part, Essex County, Docket No. FM-07-2462-23.

Adams & Caughman LLC, attorneys for appellant (Lesley Renee Adams and Harriet E. Raghnal, of counsel and on the briefs).

D.A.B., respondent pro se.

PER CURIAM

1 We use initials of the parties to protect the privacy interests of the child. R. 1:38-3(d). This Family Part appeal involves the application of the Uniform Child

Custody Jurisdiction and Enforcement Act ("UCCJEA"), N.J.S.A. 2A:34-53 to

-95, in the context of a custody dispute involving a child's father who lives in

New Jersey and a child and mother who reside in New York.

For the reasons that follow, we conclude the Family Part appropriately

applied the statute and deferred to the jurisdiction of the New York courts as the

child's "home state" during the relevant period. We therefore affirm the Family

Part's order declining jurisdiction, without prejudice to potential future

proceedings that may be appropriate.

I.

Before we discuss the salient background of this case, a brief discussion

of the UCCJEA is useful.

"The UCCJEA governs the determination of subject matter jurisdiction in

interstate, as well as international, custody disputes." Sajjad v. Cheema, 428

N.J. Super. 160, 170 (App. Div. 2012). New Jersey's version of the UCCJEA is

modeled after the uniform statute promulgated by the National Conference of

Commissioners on Uniform State Laws in 1997. Griffith v. Tressel, 394 N.J.

Super. 128, 138 (App. Div. 2007). The uniform statute has been adopted by all

fifty states. Ibid.

A-1062-23 2 The UCCJEA has important practical objectives affecting the welfare and

legal status of children. The statute "should be interpreted so as to avoid

jurisdictional competition and conflict and require cooperation with courts of

other states as necessary to ensure that custody determinations are made in the

state that can best decide the case." Ibid. The goal of the statute is to resolve

disputes over which court has jurisdiction over a child's custody expeditiously

and definitively. See N.J.S.A. 2A:34-59 (jurisdictional questions in child

custody proceedings "shall be given priority on the calendar and handled

expeditiously").

The UCCJEA, specifically N.J.S.A. 2A:34-65(a), "is the exclusive

jurisdictional basis for making a child custody determination by a court of this

State." N.J.S.A. 2A:34-65(b). Subsection a. empowers our courts with

jurisdiction if New Jersey is the child's "home state."2 Further, New Jersey

courts have jurisdiction if the child has no home state or the home state has

declined jurisdiction and the child has a "significant connection" with New

Jersey, if the child's home state declines jurisdiction after finding New Jersey is

2 "'Home state' is defined as the state in which a child lived with a parent or person acting as a parent for at least six consecutive months immediately before the commencement of a child custody proceeding." N.J.S.A. 2A:34-54. A-1062-23 3 the more appropriate forum, or if no state would otherwise have jurisdiction.

N.J.S.A. 2A:34-65(a)(1) to (4).

A temporary absence generally will not affect the child's home state status.

"The statutory definition of 'home state' allows the child's 'temporary absence'

from the home state within the six month period." Sajjad, 428 N.J. Super. at

173 (quoting N.J.S.A. 2A:34-54). In considering whether an absence is

temporary, courts have weighed several factors: "(1) the parent's purpose in

removing the child from the state, rather than the length of the absence . . . ; (2)

whether the parent remaining in the claimed home state believed the absence to

be merely temporary . . . ; (3) whether the absence was of indefinite duration,

. . . and (4) the totality of the circumstances surrounding the child's absence."

Ibid. (citations omitted).

"If New Jersey is the child's home state, the next inquiry [under the

UCCJEA] is whether custody proceedings had been commenced in another state,

properly exercising jurisdiction, which issued an initial custody determination.

N.J.S.A. 2A:34–70a." Id. at 174. "If so, and the other court had jurisdiction

‘substantially in conformity with [the UCCJEA],’ then New Jersey must stay its

proceedings and communicate with the other court, seeking an agreement on

whether New Jersey is the more convenient forum to make the determination.

A-1062-23 4 N.J.S.A. 2A:34–70b." Ibid. "A Family Part judge may decline to exercise

jurisdiction if the person seeking to invoke the jurisdiction engaged in

unjustifiable conduct, N.J.S.A. 2A:34–72, or if New Jersey is an inconvenient

forum and another state would be more appropriate. N.J.S.A. 2A:34–71." Ibid.

II.

Given this backdrop, we summarize the factual and procedural

circumstances of this case that are pertinent to the UCCJEA's application.

Background Facts

The parties were married in Guyana in 2018. Plaintiff B.D., the child's

father, is a dual citizen of Guyana and the United States. Defendant D.A.B., the

child's mother, is a citizen of Guyana.

Defendant moved into plaintiff's house in New Jersey in 2020. Their

child, J.D., was born in May 2020 in New Jersey. J.D. lived in plaintiff's home

until August 2020, when defendant and the child moved to Guyana with

plaintiff's consent. Defendant and J.D. resided in Guyana except for two one-

month visits to plaintiff in New Jersey in 2021.

Defendant and J.D. visited plaintiff again in New Jersey in August 2022.

Plaintiff purchased plane tickets for them to return on September 1 to Guyana.

Instead of boarding the plane, and allegedly out of fear plaintiff would renege

A-1062-23 5 on his promise to pursue United States citizenship for her, defendant took the

child to family members in Maryland for three months and then moved to New

York in January 2023, where they thereafter remained except for a 17-day trip

to Florida in May.

The New Jersey and New York Separate Filings and Proceedings

On May 8, 2023, plaintiff filed in the Family Part a complaint for divorce

against defendant, along with an order to show cause ("OTSC"), seeking

temporary physical custody of the child. The OTSC was denied without

prejudice because plaintiff was then unable to serve defendant.

Defendant was not served with the divorce complaint and OTSC until

October 5, 2023, when defendant met plaintiff, at his invitation, for dinner in

New Jersey. The parties left the child during the dinner with plaintiff's parents

in New York, after which he refused to return the child to defendant.

Defendant did not attend an initial custody hearing on October 10 before

the Family Part.

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Related

Neger v. Neger
459 A.2d 628 (Supreme Court of New Jersey, 1983)
Griffith v. Tressel
925 A.2d 702 (New Jersey Superior Court App Division, 2007)
Manalapan Realty v. Township Committee of the Township of Manalapan
658 A.2d 1230 (Supreme Court of New Jersey, 1995)
In Re the J.I.S. Industrial Service Co. Landfill
539 A.2d 1197 (Supreme Court of New Jersey, 1988)
Matter of Defrank v. Wolf
2020 NY Slip Op 126 (Appellate Division of the Supreme Court of New York, 2020)
Sajjad v. Cheema
51 A.3d 146 (New Jersey Superior Court App Division, 2012)
B.G. v. L.H.
163 A.3d 375 (New Jersey Superior Court App Division, 2017)

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B.D. v. D.A.B., Counsel Stack Legal Research, https://law.counselstack.com/opinion/bd-v-dab-njsuperctappdiv-2024.