Marriage of McHale v. McHale

109 P.3d 89, 210 Ariz. 194, 447 Ariz. Adv. Rep. 3, 2005 Ariz. App. LEXIS 36
CourtCourt of Appeals of Arizona
DecidedMarch 8, 2005
Docket1 CA-CV 04-0022
StatusPublished
Cited by17 cases

This text of 109 P.3d 89 (Marriage of McHale v. McHale) is published on Counsel Stack Legal Research, covering Court of Appeals of Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marriage of McHale v. McHale, 109 P.3d 89, 210 Ariz. 194, 447 Ariz. Adv. Rep. 3, 2005 Ariz. App. LEXIS 36 (Ark. Ct. App. 2005).

Opinion

OPINION

WINTHROP, J.

¶ 1 Michael J. MeHale (“Father”) appeals the trial court’s order accepting jurisdiction over the petition for contempt and modification of child support filed by Christine E. MeHale (“Mother”). Reviewing de novo, we conclude that the trial court appropriately accepted jurisdiction over the enforcement aspects of Mother’s petition, but erred by accepting jurisdiction to modify the original order of support.

FACTUAL AND PROCEDURAL HISTORY

¶2 Mother and Father were married in New Jersey in 1993. In 2000, Mother filed a petition for dissolution of marriage in Mari-copa County Superior Court. At that time, both parties and their minor child resided in Scottsdale, Arizona. The dissolution order and decree, filed in 2001, provided for joint custody and ordered Father to pay Mother $472 per month in child support beginning January 1, 2001. Mother and the child moved to Texas, and Father moved to California.

113 In July 2003, Mother filed a petition regarding contempt and seeking modification of child support in Maricopa County Superior Court. The petition alleged that Father had not paid child support since December 2002, and Mother requested that the court order Father pay $4490 in arrears plus interest. In addition, Mother alleged that Father had not qualified for the 111-day visitation adjustment in his child support obligation, and she contended that child support should therefore be modified to $695 per month. Finally, Mother requested costs and attorneys’ fees.

¶4 Father filed a motion to dismiss the petition. He argued that the superior court lacked continuing, exclusive jurisdiction to enforce or modify its support order under Arizona Revised Statutes (“A.R.S.”) section 25-626(A) (2000) because the parties and the minor child had moved out of Arizona. However, Father agreed to submit to personal jurisdiction in Texas for the purpose of modification and enforcement of child support. Father requested attorneys’ fees as well.

¶ 5 At the evidentiary hearing in November 2003, the trial court denied Father’s motion to dismiss on the ground that A.R.S. § 25-626(A) and (B) granted the court continuing jurisdiction to enforce and/or modify *196 the pre-existing support order because “the order has not been modified by a court of another state.” The court ordered Father to pay arrears, found that a substantial and continuing change in circumstances warranted that Father pay Mother a much larger amount of support, and awarded Mother costs and attorneys’ fees.

¶ 6 Father timely appealed the superior court’s order. See ARCAP 9(a). We have jurisdiction over this appeal pursuant to A.R.S. § 12-2101 (2003).

STANDARD OP REVIEW

¶ 7 Our review centers on the interpretation of the jurisdictional restrictions presented by the Uniform Interstate Family Support Act (“UIFSA”) 1 as adopted by our state legislature. See A.R.S. §§ 25-621 to -661 (2000). 2 Here, we limit our de novo review to the superior court’s construction and application of A.R.S. § 25-626(A) and (B). See Williams v. Williams, 166 Ariz. 260, 264, 801 P.2d 495, 499 (App.1990) (“Interpretation of a statute involves the resolution of legal rather than factual issues. Accordingly, we are not bound by the trial court’s conclusions of law and conduct our review de novo.” (Citation omitted.)); cf. In re Marriage of Metz, 31 Kan.App.2d 623, 69 P.3d 1128, 1130 (2003) (“Whether the trial court has the authority under UIFSA to modify its child support order involves subject matter jurisdiction, which is a question of law over which this court has unlimited review.”) (citing In re Marriage of Abplanalp, 27 Kan.App.2d 833, 7 P.3d 1269 (2000)).

ANALYSIS

¶ 8 Father does not appeal the portion of the superior court’s order enforcing the pre-existing child support order. He challenges only the court’s jurisdiction to modify the pre-existing order given that the parties and their minor child reside in states other than Arizona. The relevant portion of the statute governing jurisdiction in this case, A.R.S. § 25-626, provides as follows:

A. A tribunal of this state issuing a support order consistent with the law of this state has continuing, exclusive jurisdiction over a child support order as long as this state remains the residence of the obligor, the individual obligee or the child for whose benefit the support order is issued or until each individual party has filed written consent with the tribunal of this state for a tribunal of another state to modify the order and assume continuing, exclusive jurisdiction.
B. A tribunal of this state issuing a child support order consistent with the law of this state shall not exercise its continuing jurisdiction to modify the order if the order has been modified by a tribunal of another state pursuant to a law substantially similar to this article.

(Emphasis added.) 3

¶ 9 Turning to the language of A.R.S. § 25-626(A) and (B), subsection (A) provides *197 that an Arizona court retains continuing, exclusive jurisdiction “as long as” a party or related child remains in Arizona, “or until” each party has filed written consent to jurisdiction elsewhere. Father interprets this language to mean that the superior court retains jurisdiction to modify until either of these two provisions in subsection (A) may be invoked. Here, the “as long as” provision is no longer met; therefore, Father contends, the superior court no longer has jurisdiction to modify the pre-existing order. Father also points out that “subsection (B) of the statute does not grant the trial court any independent or additional authority to modify its prior child support orders”; instead, Father argues, subsection (B) imposes an additional restriction on the trial court’s continuing authority when such authority exists under subsection (A).

¶ 10 By contrast, Mother asserts that, when subsections (A) and (B) are read together, it becomes clear that when all parties and children have left the state, the superior court retains jurisdiction to modify until either

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Bluebook (online)
109 P.3d 89, 210 Ariz. 194, 447 Ariz. Adv. Rep. 3, 2005 Ariz. App. LEXIS 36, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marriage-of-mchale-v-mchale-arizctapp-2005.