Case Update (14 Oct 2026): Lappas v. Mobbs-Lappas; Connecticut refuses to defer to English divorce filed while Wife was still domiciled in Connecticut
The parties met in England and moved to Connecticut in June 2022. They signed a prenuptial agreement and married there that summer. Their son, who has developmental disabilities, was born in Connecticut in December 2023. In December 2025, they bought a home together in Connecticut. In January 2026, the family flew to England on roundtrip tickets for the Husband’s graduation and a visit with the Wife’s family, with a return flight booked for February 1. During the trip, the parties argued about the child. The Wife left with him and did not tell the Husband where she was going. She filed for divorce in England on February 2, the day after the family was due back in Connecticut, and told the English court she was domiciled in England. An English court has since denied the Husband’s Hague Abduction Convention petition for the child’s return to Connecticut. The Husband filed his own divorce complaint in Connecticut on May 14, 2026. The Wife moved to dismiss it because her English case was already pending.
After an evidentiary hearing, the court denied the motion. Relying on long-standing Connecticut precedent, the court explained that it will not recognize a foreign divorce unless at least one spouse was domiciled in that country. Jurisdiction is pinned down on the date a case is filed. The question was therefore not where the Wife lives now, but where she was domiciled on February 2, 2026. The court accepted that she is domiciled in England today. On the date she filed, however, she was domiciled in Connecticut. The parties had lived there for almost four years, married there, signed their prenup there, had their child there, and bought a home there only a month before the trip. The Wife herself testified that she intended to return. It is not clear from the opinion how domicile is defined under English law, or on what basis the English court accepted jurisdiction over the Wife’s divorce. The opinion addresses neither question.
The court expressly declined to rule on custody, the validity of the prenup, or the Wife’s reasons for staying in England, and left those issues for the Connecticut divorce case. The English court refused to order the child’s return under the Abduction Convention, but a decision on return is not a decision on custody, so the parenting arrangement remains unresolved. Presumably, Connecticut will look to the UCCJEA to decide whether its court has jurisdiction to make a custody determination. If any custody case was filed in England, it will also decide whether the English court had jurisdiction in substantial conformity with the UCCJEA, which would require Connecticut to defer to it.
