Thai v. Cao CA6

CourtCalifornia Court of Appeal
DecidedJune 5, 2025
DocketH052338
StatusUnpublished

This text of Thai v. Cao CA6 (Thai v. Cao CA6) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thai v. Cao CA6, (Cal. Ct. App. 2025).

Opinion

Filed 6/4/25 Thai v. Cao CA6 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SIXTH APPELLATE DISTRICT

TIEN PHAN THAI, H052338 (Santa Clara County Plaintiff and Respondent, Super. Ct. No. 20FL003621)

v.

THUY DUNG THI CAO,

Defendant and Appellant.

In this dissolution and custody proceeding, Mother appeals a trial court order clarifying that California is the home state for the couple’s minor child pursuant to the Uniform Child Custody Jurisdiction Enforcement Act (UCCJEA). Mother argues the trial court lacked the authority to issue the order—which she contends constituted a sua sponte reconsideration of a previous order which had determined that Vietnam was the child’s home state—because the time to appeal the previous order had run, and because the trial court improperly conducted a new hearing with new evidence. Mother also argues that the trial court erred in conducting the UCCJEA home state analysis, and improperly declined to recognize and enforce a 2023 judgment issued by a Vietnamese court purportedly awarding her custody of the child. Father moved to dismiss the appeal on the ground that the challenged order was not a final appealable order, and that Mother failed to obtain the requisite certificate of probable cause to appeal an interlocutory order pursuant to Code of Civil Procedure section 904.1, subdivision (a)(10), and Family Code section 2025. Mother contends the order was a final appealable order pursuant to Code of Civil Procedure section 904.1, subdivision (a)(14), for “a final order or judgment in a bifurcated proceeding regarding child custody or visitation rights.” We conclude the challenged order is a final appealable order and we deny Father’s motion to dismiss. On the merits, we conclude the trial court had the authority to issue the challenged order, and it properly determined that California is the child’s home state pursuant to the UCCJEA. Accordingly, we affirm. I. FACTUAL AND PROCEDURAL BACKGROUND A. Marriage and dissolution Tien Phan Thai (Father) and Thuy Dung Thi Cao (Mother) were married on March 11, 2016, in Vietnam. Their daughter was born on June 14, 2016, in Vietnam (child 1). On March 13, 2020, Mother gave birth to another daughter in San Jose, California (child 2). Subsequent paternity tests in July 2021 established that Father was not the biological father of child 2. Father petitioned for dissolution on October 23, 2020. Around the same time, he also filed a request for a child abduction prevention order, in which he stated that Mother had “moved here from Vietnam in January of 2020 and has made statements to the effect that she intends to go back,” and “take the children with her.”1 Mother submitted her response to the petition on November 20, 2020, in which she requested sole physical custody of the children, with Father receiving visitation rights.

1 The copy of Father’s request included in the record is signed and dated by Father as of October 22, 2020, although it does not include a file-stamp. In the trial court proceedings, both parties asserted that the request was filed on November 9, 2020, although there is no document in the record with that date on it.

2 B. Initial UCCJEA home state determination In connection with the dissolution proceeding, the parties submitted UCCJEA declarations. In her declaration filed on November 23, 2020, Mother stated that child 1 had been living with her and Father at a residence in San Jose since January 2020, and child 2 had been living with them at the same residence since her birth on March 13, 2020.2 The trial court held a hearing on November 30, 2020. The minute order for that hearing (November 2020 minute order) states that the court made the following findings: “3048 findings as to [child 1] for the State of California and Santa Clara County [¶] Vietnam is the home state for [child 2].”3 According to the November 2020 minute order, the court also ordered that: (1) the children not be removed from California; (2) the parties engage in mediation; (3) Father have temporary non-supervised visitation rights every Saturday from 10:00 a.m. to 06:00 p.m.; and (4) Father’s counsel shall maintain the children’s passports.

2 Father’s UCCJEA declaration does not appear to be part of the record. However, there is no dispute that the children had been living at the residence in San Jose from January 2020 and March 2020, respectively. 3 Family Code section 3048 provides that “in a proceeding to determine child custody or visitation with a child, every custody or visitation order shall contain” certain specified findings, and that “[i]n cases in which the court becomes aware of facts that may indicate that there is a risk of abduction of a child, the court shall, either on its own motion or at the request of a party, determine whether measures are needed to prevent the abduction of the child by one parent. To make that determination, the court shall consider the risk of abduction of the child, obstacles to location, recovery, and return if the child is abducted, and potential harm to the child if the child is abducted,” by considering additional specified factors. (Fam. Code, § 3048, subd. (a), (b)(1).) Further, it provides that “[i]f the court makes a finding that there is a need for preventative measures after considering the factors listed in paragraph [(b)(1)], the court shall consider taking one or more of the following measures to prevent the abduction of the child [such as]: [i]ncluding provisions in the custody order to facilitate use of the [UCCJEA] and the Hague Convention on the Civil Aspects of International Child Abduction [citation], such as identifying California as the home state of the child or otherwise defining the basis for the California court’s exercise of jurisdiction.” (Fam. Code, § 3048, subd. (b)(2)(J).)

3 On February 10, 2021, the trial court issued its findings and order after hearing for the November 30, 2020, hearing (February 2021 order). The February 2021 order stated, contrary to the November 2020 minute order, that: “As to [child 2], California is the home state [and] California has jurisdiction to make custody and visitation orders for that child. [¶] As to [child 1], Vietnam is the home state or country as defined and Vietnam has jurisdiction to make custody and visitation orders for that child.” The court also ordered that neither child “shall be removed from the State of California without a court order.” C. Subsequent proceedings The trial court held another hearing on February 18, 2021. The minute order for that hearing states that the trial court “takes temporary emergency jurisdiction over the minor child, [child 2] DOB: 06/14/2016.” The minute order thus listed the date of birth for child 1, but with child 2’s name. The minute order also provided that “[t]he minor child may not leave the United States till further order of the Court,” and “[c]ustody and visitation is reserved till the trial on the DVRO on 7/7/2021.” The trial court’s findings and order after hearing for the February 18, 2021, hearing is signed and dated December 10, 2021, and file-stamped December 17, 2021. That order stated the court was issuing “the following temporary orders: The Court takes temporary emergency jurisdiction over the minor child, [child 1] DOB: 06/14/2016 [¶] The minor child may not leave the United States till further order of the Court [¶] [c]ustody and visitation is reserved till the trial on the DVRO on 7/7/2021.” This order thus appears to reflect the correct date of birth for child 1. Another hearing was held on September 29, 2021.

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