In Re the Relationship of Henry

951 P.2d 135, 326 Or. 166, 1997 Ore. LEXIS 594
CourtOregon Supreme Court
DecidedDecember 18, 1997
DocketCC 93-DR-1084; CA A89111; SC S43648
StatusPublished
Cited by10 cases

This text of 951 P.2d 135 (In Re the Relationship of Henry) is published on Counsel Stack Legal Research, covering Oregon Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re the Relationship of Henry, 951 P.2d 135, 326 Or. 166, 1997 Ore. LEXIS 594 (Or. 1997).

Opinion

*168 GRABER, J.

The issue before us in this interstate custody dispute is whether the federal Parental Kidnaping Prevention Act (PKPA), 28 USC § 1738A (1994), and the Uniform Child Custody Jurisdiction Act (UCCJA), ORS 109.700 to 109.930, allow Oregon to modify a particular California custody decree. The trial court modified the decree, and the Court of Appeals affirmed. Henry and Keppel, 143 Or App 203, 205, 922 P2d 712 (1996). We reverse the decision of the Court of Appeals and remand the case to the trial court for farther proceedings.

The Court of Appeals reviewed the facts in this case de novo, pursuant to ORS 19.125(3). Ibid. As permitted by ORS 19.125(4), we limit our review to questions of law and take the following facts from the findings of the Court of Appeals.

“Mother and father, who never married, began living together in California in the spring of 1983. Their daughter was born in July 1984. After the parties separated in July 1985, mother moved with the child to Oregon, where they have resided ever since. In December 1985, father began a proceeding in California to establish paternity and joint custody. Mother sought sole custody. In October 1987, the California court ordered joint legal custody, with physical custody awarded to mother. Father was granted visitation, including all but three weeks of summer vacation, spring break, and half of the Christmas holidays. Father exercises those visitation rights in California and, two to four times a year, he spends four days with his daughter, either in California or in Oregon.
“In June 1988, father filed an action in Jackson County to enforce the California order against mother. Mother was never served. Five years later, mother moved to change the venue of father’s enforcement action to Josephine County. Over father’s objection, her motion was granted. In March 1994, mother obtained an order to show cause in Josephine County, seeking sole custody and limiting father’s visitation. Father moved to dismiss the modification proceeding for lack of jurisdiction. The court denied father’s motion, as *169 well as his later motion for reconsideration. The court modified the California decree to award mother sole legal custody and to modify father’s visitation.” Ibid, (footnote omitted).

Father appealed the trial court’s judgment, arguing that the court erred in modifying the decree because, under the PKPA and the UCCJA, California courts have continuing jurisdiction over this matter. Mother argued that California does not have continuing jurisdiction in the circumstances and that an Oregon court can modify the decree. The Court of Appeals affirmed, holding that there is not “substantial evidence” on the custody matter in California and, therefore, that Oregon can modify the decree. Id. at 208-09. This court allowed father’s petition for review.

To place our discussion of the specific issues in context, we recount briefly the history of both the UCCJA and the PKPA. The Commissioners on Uniform State Laws drafted the UCCJA in 1968 to resolve jurisdictional conflicts in child custody cases and to promote recognition and enforcement of out-of-state custody decrees. Grubs v. Ross, 291 Or 263, 268-69, 630 P2d 353 (1981). AH states have adopted some form of the UCCJA. Anne B. Goldstein, The Tragedy of the Interstate Child: A Critical Reexamination of the Uniform Child Custody Jurisdiction Act and the Parental Kidnaping Prevention Act, 25 UC Davis L Rev 845, 849 (1992). Oregon has codified the UCCJA at ORS 109.700 to 109.930. See Stubbs v. Weathersby, 320 Or 620, 624-25, 892 P2d 991 (1995) (summarizing the purposes of the UCCJA, as set forth in ORS 109.720(1)).

According to the United States Supreme Court, the UCCJA did not achieve its goal of resolving jurisdictional disputes. See Thompson v. Thompson, 484 US 174, 181, 108 S Ct 513, 98 L Ed 2d 512 (1988) (so stating). Contributing to that failure were the lack of uniformity in the versions of the UCCJA adopted by the various states and the refusal by some courts to give full faith and credit to foreign custody decrees on the ground that such decrees are subject to modification in keeping with the best interests of the child. Id. at 180-81. In 1980, Congress attempted to resolve jurisdictional disputes by enacting the PKPA “to provide for nationwide *170 enforcement of custody orders made in accordance with the terms of the UCCJA.” ZcZ. at 181.

Because the PKPA is a federal law and the UCC JA is a state law, in examining the relationship between them we consider whether the doctrine of federal preemption applies. In general, under the Supremacy Clause, Congress has the power to enact an otherwise valid law that preempts state law, 1 and it may preempt state law in one of three ways. “Federal preemption may occur “by express provision, by implication, or by a conflict between federal and state law.’ ” Shaw v. PACC Health Plan, Inc., 322 Or 392, 398, 908 P2d 308 (1995) (quoting New York Blue Cross v. Travelers Ins., 514 US 645, 654, 115 S Ct 1671, 131 L Ed 2d 695 (1995)). See also Laurence H. Tribe, American Constitutional Law (2d ed 1988) § 6-25, at 481 n 14 (explaining the three types of preemption). In deciding whether a federal law preempts a state law, a court’s task is to determine whether Congress intended for the federal law in question to supersede state law. Shaw, 322 Or at 398 (citing Shaw v. Delta Air Lines, Inc., 463 US 85, 95, 103 S Ct 2890, 77 L Ed 2d 490 (1983)).

The United States Supreme Court has been reticent to find that federal law preempts state law in the area of domestic relations. In that field, the Court has asked “whether Congress has ‘positively required by direct enactment’ that state law be pre-empted. Wetmore v. Markoe, 196 US 68, 77[, 25 S Ct 172, 49 L Ed 390] (1904).” Hisquierdo v. Hisquierdo, 439 US 572, 581, 99 S Ct 802, 59 L Ed 2d 1 (1979).

Here, Congress expressly has required in the PKPA that state law respecting certain proceedings to modify child custody determinations be preempted:

*171 “The appropriate authorities of every State shall enforce according to its terms, and shall not modify except as provided in subsection (f) of this section, any child custody determination

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Bluebook (online)
951 P.2d 135, 326 Or. 166, 1997 Ore. LEXIS 594, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-relationship-of-henry-or-1997.