Case Update (24 April 2026): KC v. MJP; New Hampshire child support ruling entitled to FFC in New York

This case is one that was fully litigated already in New Hampshire. In February 2025, the New Hampshire Supreme Court affirmed its lower court’s refusal to register a Mexican child support order. The parent who obtained the Mexican child support order had sought to register that order in New Hampshire against the paying parent, who was a resident of that state. The parties had previously resolved custody of their minor child in a New York custody order. The parent who secured the child support order also later sought to register the Mexican order in New York. She also sought to register a second Mexican order of contempt in New York. After some significant motion practice, the U.S.-based parent’s lawyer sought a ruling on whether the New Hampshire decision should be afforded full faith and credit in New York. At this stage, the matter was before a Support Magistrate. The Support Magistrate concluded it was entitled to full faith and credit, and therefore, New York should not register the Mexican orders. The Mother sought relief with the Family Court. She argued that the Support Magistrate should have assessed the case squarely under New York’s enactment of the Uniform Interstate Family Support Act, and not defer to New Hampshire’s analysis, under its version of UIFSA. She also argued she had not been afforded the full and fair opportunity to litigate in NH.

The NY Family Court concluded that the Support Magistrate’s findings are entitled to great deference and should not be disturbed unless no fair interpretation of the evidence can support the findings. The Family Court concluded “[t]he Support Magistrate correctly applied the doctrine of Full Faith and Credit. New Hampshire’s determination was based on a valid defense under UIFSA. Both New York and New Hampshire have adopted identical codifications of the lack of personal jurisdiction defense under UIFSA. Here, the New Hampshire Supreme Court conclusively determined that Mexico did not have personal jurisdiction over the Respondent, a defense which is explicitly articulated under UIFSA. As such, the Support Magistrate correctly determined that New York is under an obligation under the Full Faith and Credit Clause of the U.S. Constitution to recognize New Hampshire’s determination was that Mexico lacked personal jurisdiction over the Petitioner under UIFSA.” Further, the Full Faith and Credit for Child Support Orders Act (FFCCSOA) requires each state to give full faith and credit to another state’s validly issued child support orders, and plainly states that a child support order without personal jurisdiction does not have continuing, exclusive jurisdiction. The New Hampshire ruling “renders the Mexican orders unenforceable in all states, including New York.” The Parent in Mexico also had a full and fair opportunity to litigate in New Hampshire, as indicated by the record. She was afforded her day in court. If the Family Court agreed with the Mother’s argument, nothing could stop her “from essentially moving from state to state and repeatedly relitigating the issue.”

New York recognized the New Hampshire order, and vacated the registration of the two Mexican support orders.