Case Update (24 Sept 2026): Cooley v. Cooley; Pennsylvania enforces Ontario child support order under the Hague Child Support Convention, rejecting the father's public policy defense

The parties married in 2012 and lived in Toronto with their two children, both of whom have special needs. After they separated in 2017, the Father, a self-employed attorney, returned to Pittsburgh but kept an apartment near Toronto and exercised parenting time there. He started the divorce and custody case in Ontario and later agreed that Ontario would keep jurisdiction over child support. When the Mother pursued support, however, he refused to produce financial disclosure, ignored costs orders, and argued that any Ontario order would be unenforceable against him in Pennsylvania. The Ontario court struck his pleadings, proceeded to an uncontested trial, and in March 2024 entered a final order for CAD 4,393 per month, 32% of the children's special expenses, and more than CAD 264,000 in arrears. The Mother registered the order in Allegheny County under Pennsylvania's UIFSA provisions implementing the 2007 Hague Child Support Convention, and the Father contested it.

The Father raised only one of the ten refusal grounds: that enforcement would be manifestly incompatible with public policy. He offered three reasons. First, the Mother should have played an "away game" by sending her claim to Pennsylvania under Ontario's reciprocal legislation. Second, being defaulted without an opportunity to appear at trial violated due process. Third, Ontario's percentage-of-income guidelines, which ignore the higher-earning Mother's income, conflict with Pennsylvania's income shares model. The Superior Court rejected all three. An obligee needs to go to the obligor's home forum only when the issuing court lacks a sufficient nexus with the obligor, and Ontario had at least three UIFSA long-arm bases here. Striking pleadings for willful discovery violations mirrors what Pennsylvania's own rules permit. And applying a different support model is not, on its own, a public policy violation, particularly when the Father's refusal to disclose meant no one could say what Pennsylvania's guidelines would have produced. The court affirmed registration, leaving the Father's remedy as modification by a tribunal with jurisdiction.