McCormick v. Robertson

Father, a Missouri resident, filed parentage and custody complaint in Champaign County, where he then lived. Circuit court erred in vacating as void a parentage and custody order, and in dismissing father's complaint with prejudice on grounds that at the time cause of action was brought, court lacked subject matter jurisdiction to hear and decide it as provisions of UCCJEA had not been met. Child was born in Missouri, mother had resided in Missouri, but moved to Nevada with child. UCCJEA applies only to proceedings in initial custody determination. Champaign County was appropriate forum to determine parentage, and to enter judgment of parentage, custody, and related matters. Even if circuit court's decision to proceed despite deficiencies of father's claim under UCCJEA was error, it still had subject matter jurisdiction. (GARMAN, FREEMAN, THOMAS, KILBRIDE, BURKE, and THEIS, concurring.)