State ex rel. M.L. v. O'Malley
Annotate this CaseMother and Father, who never married, were the parents of Daughter. Mother later moved to New Jersey with Daughter. When Father’s first application to determine custody of Daughter in the Cuyahoga County Juvenile Court was unsuccessful, Father filed a second application to determine custody. Mother filed an application in a New Jersey family court to transfer jurisdiction to New Jersey. The New Jersey family court denied Mother’s application and ordered that Ohio retain jurisdiction, concluding that Ohio had home-state jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). Mother sought a writ of prohibition, asserting that the case should proceed in New Jersey. The court of appeals denied the writ. The Supreme Court affirmed, holding (1) Mother was ineligible for a writ of prohibition because the jurisdiction issue was litigated in both Ohio and New jersey, and both courts concluded that Ohio was Daughter’s home state for purposes of the UCCJEA; and (2) moreover, Mother had an adequate remedy by way of appeal of both the Ohio and New Jersey decisions regarding jurisdiction, as well as the juvenile court’s custody decision.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.