Marriage of Sawyer

James Sawyer (plaintiff) and Rosemary Sawyer (defendant) divorced in Minnesota. In the divorce decree, James was ordered to pay child support, and Rosemary received custody of their two children. Shortly after the divorce, James relocated to California, and Rosemary registered the Minnesota child-support order in California for enforcement pursuant to the Uniform Interstate Family Support Act (UIFSA). Over the next several years, James had periodic residential custody of the children. In 2001, following a support enforcement hearing, the Minnesota court, in relevant part, ordered James to pay Rosemary approximately $90,000 in child-support arrears. Neither Rosemary nor James challenged the arrears determination. In 2005, Rosemary registered the 2001 Minnesota arrears judgment in California. The California court promptly notified James about the registration. James did not timely challenge the validity of the arrears judgment within the relevant 20-day challenge window. In 2018, California notified James that the Minnesota Department of Child Support (DCS) (defendant) had registered an updated arrears enforcement order based on the 2001 arrears judgment. James moved to vacate the 2018 enforcement order, arguing that the underlying 2001 arrears judgment was invalid. DCS challenged, arguing that because James had failed to timely challenge the 2001 arrears judgment after it was registered in California in 2005, he was precluded from doing so. The trial court denied James’s motion to vacate but stayed enforcement of a portion of the arrears on equitable grounds to account for the times James had assumed residential custody of the children. James and DCS both appealed.