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Family Law Keyed to Weisberg
LeTellier v. LeTellier
Facts
In 1989 the District of Columbia entered an order adjudging Steven LeTellier to be the father of Teresa LeTellier’s son, Nicholas. The court awarded custody to Teresa and ordered Steven to pay child support. Teresa and Nicholas later moved to Tennessee, and Steven moved to Virginia. In 1998 Teresa filed petitions in the Juvenile Court in Tennessee seeking to enroll the District Court of Columbia order and to modify the child support award. The court granted Steven’s motion to dismiss on grounds that the Tennessee court lacked subject matter jurisdiction and ordered that the case be transferred back to Virginia. The Court of appeals reversed, finding that the jurisdictional provisions of Tennessee’s Uniform Interstate Family Support Act (UIFSA) conflict with the Federal Full Faith and Credit for Child Support Orders Act (FFCCSOA) and that FFCCSOA preempted UIFSA.
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