Barndt v. Barndt

CERCONE, Judge,

concurring:

I agree that the order of the lower court awarding custody to appellee Joel Barndt should be vacated because the lower court lacked subject matter jurisdiction to hear the custody issue presented by this case. While the courts of this Commonwealth generally have jurisdiction in custody matters, where there is a prior order of custody in another state involving the same parties and the same *346children, the courts of this Commonwealth lack subject matter jurisdiction to modify that decree under both the Uniform Child Custody Jurisdiction Act (UCCJA), enacted in Pennsylvania at 42 Pa.C.S.A. § 5341 et seq., and the federal Parental Kidnapping Prevention Act (PKPA), 28 U.S.C. § 1738A. To hold otherwise would be to defeat the purposes of both enactments, which include, inter alia, to:

(1) Avoid jurisdictional competition and conflict with courts of other states in matters of child custody which have in the past resulted in the shifting of children from state to state with harmful effects on their well-being.
(4) Discourage continuing controversies over child custody in the interest of greater stability of home environment and of secure family relationships for the child.
(5) Deter abductions and other unilateral removals of children undertaken to obtain custody awards.
(6) Avoid relitigation of custody decisions of other states in this Commonwealth insofar as feasible.
(7) Facilitate the enforcement of custody decrees of other states.

42 Pa.C.S.A. § 5342. Accord 28 U.S.C. § 1738A (Congressional Findings and Declaration of Purposes for Parental Kidnapping Prevention Act of 1980).

UCCJA requires that the state of the initial custody decree have exclusive continuing jurisdiction of custody matters involving the original parties and children. See 42 Pa.C.S.A. § 5355; Commonwealth ex rel. Zaubi v. Zaubi, 275 Pa.Super. 294, 418 A.2d 729, aff'd 492 Pa. 183, 423 A.2d 333 (1980). It does not recognize the concept of concurrent state jurisdiction to hear a modification petition.1 The PKPA clarifies and strengthens the concept of continuing state jurisdiction to modify an original decree, a necessity which arose due to misinterpretations of UCCJA by the adopting states, as well as the existence of “havens” for *347child snatchers in states which had not enacted UCCJA.2 The language of PKPA clearly indicates the intent of Congress to require the states to give full faith and credit and not to modify the custody decrees of other states. 28 U.S.C. § 1738A(a).

In the instant case, there is no doubt that the petition for custody filed by Joel Barndt in the Court of Common Pleas of Columbia County in March, 1987 was a petition for modification because a prior award of custody had been made to appellant by order of the courts of North Dakota in May, 1983. It is further clear from the record that Michael and Kristopher Barndt were residing in Pennsylvania in March, 1987 pursuant to the “reasonable visitation” provisions granted to appellee under the North Dakota decree. The Columbia County court’s assertion of its jurisdiction in this situation set up an interstate custody dispute of the type which both UCCJA and PKPA were specifically enacted to prevent.3 It is extremely unfortunate, although understandable given the confusion this issue has generated in the courts, that the lower court in this case was not more enlightened as to the proper interpretation of the state and federal statutes regulating interstate custody issues. Had the lower court properly applied the concepts and requirements of UCCJA and PKPA in regard to petitions for modification of a valid custody order previously issued in another state, it is probable that this lengthy litigation in *348Pennsylvania could have been easily avoided along with the resultant heartbreak, uncertainty, and grief which has likely been experienced by the parties, particularly appellant, and the children. At the risk of redundancy, it cannot be too strongly emphasized that the UCCJA and PKPA were enacted to prevent this precise occurrence.

I agree with Judge Kelly that the order of the court of Columbia County of April 10, 1987 and all subsequent orders pertaining to the custody of Michael and Kristopher Barndt must be vacated, and legal custody of the children returned to appellant pursuant to the 1983 North Dakota decree. If Joel Barndt seeks modification of custody under that order, he must do so in the courts of that state.

. See Bodenheimer, Interstate Custody: Initial Jurisdiction and Continuing Jurisdiction under the UCCJA, 14 Fam.Law Q. 203, 214-17 (1981).

. See Note, The Parental Kidnapping Prevention Act — Analysis and Impact on Child Custody Jurisdiction, 27 N.Y.L.Sch.L.Rev. 553, 564-65 (1983).

. I would find North Dakota’s declination of jurisdiction in August, 1987 to be based on erroneous legal principles, including an over-reliance on Pennsylvania’s misguided assertion of jurisdiction as well as the North Dakota court’s own misinterpretation of UCCJA (enacted in that state). The North Dakota court relied on concepts relevant to the concurrent jurisdiction of two competing states in an initial determination of custody. Such considerations are not relevant to a modification petition except in unusual circumstances. See Bodenheimer, supra note 1. In addition, I would not find it proper for a Pennsylvania court to assert its jurisdiction prior to a declination of jurisdiction by the decree-issuing state, which is what occurred in the instant case. The Columbia County court should have declined jurisdiction and directed appellee to file his petition for modification of custody with the courts of North Dakota.