Roman v. KarrenAnnotate this Case
Cleveland Karren and Jayda Roman had a daughter, born March 2012 in Washington, D.C. Jayda and the daughter moved in July to Mount Vernon, Washington, to live with Jayda’s parents. The family moved to Anchorage in April 2013. Cleveland later took a job at Joint Base Lewis-McChord; he moved to Washington in April 2014, and Jayda remained in Anchorage with the daughter. In May 2015 Cleveland took a different job and moved to Washington, D.C. Jayda filed the parties’ marital dissolution petition in Anchorage in May 2015. Jayda and Cleveland testified that they both had “live[d] in Alaska six continuous months out of the past six years.” Jayda appealed the Alaska superior court’s child custody order, arguing that the court lacked subject matter jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) or that it abused its discretion by failing to decline UCCJEA jurisdiction on inconvenient forum grounds. She also contended the court gave disproportionate weight to the custody investigator’s trial testimony and, under the statutory custody factors, to maintaining the father-daughter relationship. The Alaska Supreme Court concluded that the superior court had UCCJEA jurisdiction because Alaska was the child’s home state when the proceeding commenced; the Court also concluded that the court properly weighed the statutory inconvenient forum factors and did not abuse its discretion when it determined that deciding custody in Alaska was most practical. And because the court had broad discretion in making a custody determination — including the weight to give a custody investigator’s testimony — the Supreme Court concluded the court did not abuse its discretion when weighing either testimony or statutory custody factors.