Section 27.13 Long-Arm Jurisdiction
Library | Family Law Deskbook and 2014 Supp |
B. (§27.13) Long-Arm Jurisdiction
Rule 54.06(b) provides for long-arm jurisdiction in dissolution of marriage actions initiated in Missouri:
(b) Service sufficient to authorize a general judgment in personam may be obtained on any person, any person’s personal representative, or other legal representative, whether or not a citizen or resident of the state, who has lived in lawful marriage within this state, as to all civil actions for dissolution of marriage or for legal separation and all obligations arising for maintenance of a spouse, support of any child of the marriage, attorney fees, suit money or disposition of marital property, if the other party to the lawful marriage lives in this state or if a third party has provided support to the spouse or to the children of the marriage and is a resident of this state.
In Kulko v. Superior Court of California in and for the City & County of San Francisco, 436 U.S. 84 (1978), the United States Supreme Court considered the jurisdiction of the California courts under the California long-arm statute, Cal. Civ. Proc. Code § 410.10 (Westlaw through Ch. 22 of 2012 Reg. Sess.), to modify a child support order entered in accordance with a Haitian divorce decree. The parties were married in California during one of the appellant husband’s brief visits while he was in the military. The Haitian divorce decree incorporated a New York separation agreement entered into when the parties were domiciled in New York. Following the divorce, the appellant husband sent the parties’ daughter to live with her mother in California. The California Supreme Court upheld the California court’s exercise of jurisdiction, concluding that, in sending the daughter to reside with her mother in California, the appellant husband purposefully availed himself of the benefits and protections of the laws of California.
The Supreme Court of the United States reversed, holding that the appellant husband had insufficient contacts with California to provide a constitutional basis for its courts to exercise personal jurisdiction over him. Shaffer v. Heitner, 433 U.S. 186 (1977). To comply with the due process requirements of the Fourteenth Amendment, a judgment imposing a personal duty of liability must be entered by a court having jurisdiction over the person of the defendant. Int’l Shoe Co. v. State of Wash., Office of Unemployment Comp. & Placement, 326 U.S. 310 (1945); Pennoyer v. Neff, 95 U.S. 714 (1877). The existence of valid personal...
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- Section 27.1 Introduction
- Section 27.2 Interstate Recognition of Judgments
- Section 27.3 Jurisdiction—Domicile
- Section 27.4 Domicile and Residence—Defined
- Section 27.5 Military Personnel Stationed in Missouri
- Section 27.6 Enforcement of Foreign Judgment and Collateral Attack
- Section 27.7 Jurisdiction
- Section 27.8 Burden of Proof
- Section 27.9 Res Judicata
- Section 27.10 Estoppel
- Section 27.11 In Personam Jurisdiction
- Section 27.12 Divisible Divorce Actions
- Section 27.13 Long-Arm Jurisdiction
- Section 27.14 Distribution of Property
- Section 27.15 Intangible Property
- Section 27.16 Tangible Property
- Section 27.17 Child Support
- Section 27.18 Child Custody
- Section 27.19 Repeal of Missouri Uniform Child Custody Jurisdiction Act
- Section 27.20 Missouri Uniform Child Custody Jurisdiction and Enforcement Act
- Section 27.21 Jurisdiction Under the Uniform Child Custody Jurisdiction and Enforcement Act
- Section 27.22 Initial Custody Determinations
- Section 27.23 Continuing Jurisdiction Over Custody Determinations
- Section 27.24 Modification of Custody Decree of Another State
- Section 27.25 Emergency Custody Determinations
- Section 27.26 Concurrent Proceedings
- Section 27.27 Inconvenient Forum
- Section 27.28 “Clean Hands”
- Section 27.29 Notice Requirements
- Section 27.30 Communication Between Courts
- Section 27.31 Enforcement Under the Uniform Child Custody Jurisdiction and Enforcement Act
- Section 27.32 The Hague Convention
- Section 27.33 Parental Kidnapping Prevention Act of 1980
- Section 27.34 Marriage
- Section 27.35 Annulment
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