Thompson v. Thompson

The Parental Kidnapping Prevention Act (PKPA) extended the Full Faith and Credit Doctrine to child custody orders. It provided that once a state exercised jurisdiction over a custody dispute, no other state may exercise simultaneous jurisdiction. Susan Clay (formerly Susan Thompson) (defendant) initially filed a petition in California seeking dissolution of her marriage with David Thompson (plaintiff) and custody of their son, Matthew. The court initially awarded joint custody. However, when Susan moved to Louisiana, the court awarded her sole custody at least until a court investigator submitted a report on the status of the custody, at which point the court would make a more knowledgeable determination. Three months after the move, Susan filed a petition in Louisiana seeking enforcement of the California court ruling and final judgment of sole custody. The Louisiana court granted the petition and full custody of Matthew to Susan. Two months later, however, the California court completed its custody investigation and awarded sole custody to David. David then brought this suit in the District Court for the Central District of California, seeking an order declaring the Louisiana ruling invalid and the California ruling valid. Susan filed a motion to dismiss for lack of subject matter and personal jurisdiction. The District Court for the Central District of California granted the motion and the United States Court of Appeals for the Ninth Circuit affirmed. David appealed.