In re E.W.
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Mother appealed the trial court's orders declaring her son a dependent of the court and removing him from the care, custody, and control of mother, releasing the child to father and terminating jurisdiction with a custody order awarding father sole legal and physical custody. The trial court also ordered that mother have no visitation with the child.
The Court of Appeal affirmed, holding that the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) takes a strict "first in time" approach to jurisdiction. The rule, subject to exceptions inapplicable here, is that once the court of an "appropriate state" -- one having jurisdiction under Family Code 3421, subdivision (a) -- has made a child custody determination, that court obtains exclusive, continuing jurisdiction. In this case, the initial child custody determination was made by the court in Orange County on January 2, 2014.
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