Out-Of -State Support Orders Cannot Be Modified in New York

In this day and age in which parties obtain an order regarding child support in one state and then move to another jurisdiction, it is important to know that the original support order cannot be modified or even extended by a court in the second state, so said the New York Court of Appeals in the case Spencer v. Spencer.

As reported in the Times Union, the Spencers divorced in Connecticut in 1994. That same year, Mrs. Spencer and the parties’ three children moved to Albany County. The father remained in Connecticut.

At the time of the divorce, a Connecticut court ordered James Spencer to pay $250 a week for each child and to provide medical insurance. The payments were to continue until each child turned 18, when child support terminates in Connecticut.

Spencer's oldest son turned 18 in 2004, ending his father's obligation under the Connecticut order. But Susan Spencer filed a petition in Albany County in June 2005, seeking to continue payments until their son turned 21, that being "consistent with the laws of the state of New York."

The Court of Appeals declined to modify the Connecticut order or to extend Mr. Spencer’s obligation to pay support.

Under the Full Faith and Credit for Child Support Orders Act (FFCCSOS) and the Uniform Interstate Family Support Act (UIFSA), “the state issuing a child support order retains continuing, exclusive jurisdiction over its child support orders so long as an individual contestant continues to reside in the issuing state [28 USC §1738B(d) and Family Court Act §580-205]

Because the respondent continued to reside in Connecticut, the state which issued the original child support order, Connecticut retained continuing and exclusive jurisdiction, even though support for the eldest son terminated upon his reaching 18 years of age. Thus, any change to the respondent’s obligations imposed by New York would constitute an impermissible exercise of jurisdiction modifying the Connecticut order, a clear violation of FFCCSOS and UIFSA.

It would have been impermissible for a New York court to extend the support order for three years (from age 18, when the Connecticut order expired, until age 21, when child support terminates in New York).

A modification is "a change in a child support order that affects the amount, scope, or duration of the order and modifies, replaces, supersedes, or otherwise is made subsequent to the child support order" (28 USC § 1738B [b]). Here, the New York order changed the amount of the initial order (increasing it by $100 per week), the scope of the initial order (adding a provision for college expenses), and the duration of the initial order (extending the father's obligation for three years). Undoubtedly, the New York order was "made subsequent" to the Connecticut order. Therefore, under the plain language of the federal statute, a second order for child support is a "modification" of Connecticut's order.

This decision seems to make a whole lot of sense. If a party was able to modify an existing order merely by relocating, no child support order would be final. There would be nothing to prevent a party to litigate in one state and then move to another with a more favorable law. This decision clearly prevents that from

566 Responses

  1. Bob
    Why doesn't NY get with the other 47 states as NY is what looks like 1 of 3 states that continues child support to the age of 21. Based on all I have read on your site and others this should be a federal law just like adoption should be mandated by the federal Gov't as those laws are also state by state and a mess.
  2. Michael
    I'm not an attorney, but I disagree with the title of this blog entry. A case could be modified in NY if both parties moved out of the original state, and the party being sued lived in NY. However, NY would not be allowed to change the age of emancipation, because that is non-modifiable according to UIFSA. The amount of support would be modifiable. 'Age of emancipation' is determined by the original order regardless of changes in jurisdiciton.
  3. Rich
    Didn’t the opinion on this case state that if both parties lived in New York, then they could modify the order and extended the age of emancipation to 21?
  4. BJSC
    Question: The custodial parent is in NY and the non-custodial parent is in Michigan. The divorce and support order were issued in NY when both parties resided in NY. Now, the non-custodial parent paying support sends payment through MI's family court in oligation of the NY order. My question is whether both the NY courts and the MI courts can sue the non-custodial paying parent for failure to pay when a payment is late? That is, in my scenario, the non-custodial paying parent resides in MI and anytime there is a late payment, the custodial parent who lives in NY sues and now so does the MI court sue. Law suits are coming from both courts. Is that correct.
  5. Jen
    What if neither party lives in NY and both parties reside in states where support ends at 18. Can't obligator petition the court to have the jurisdiction changed.
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  254. Zune and iPod: Most people compare the Zune to the Touch, but after seeing how slim and surprisingly small and light it is, I consider it to be a rather unique hybrid that combines qualities of both the Touch and the Nano. It's very colorful and lovely OLED screen is slightly smaller than the touch screen, but the player itself feels quite a bit smaller and lighter. It weighs about 2/3 as much, and is noticeably smaller in width and height, while being just a hair thicker.
  255. Apple now has Rhapsody as an app, which is a great start, but it is currently hampered by the inability to store locally on your iPod, and has a dismal 64kbps bit rate. If this changes, then it will somewhat negate this advantage for the Zune, but the 10 songs per month will still be a big plus in Zune Pass' favor.
  256. The new Zune browser is surprisingly good, but not as good as the iPod's. It works well, but isn't as fast as Safari, and has a clunkier interface. If you occasionally plan on using the web browser that's not an issue, but if you're planning to browse the web alot from your PMP then the iPod's larger screen and better browser may be important.
  257. Sorry for the huge review, but I'm really loving the new Zune, and hope this, as well as the excellent reviews some other people have written, will help you decide if it's the right choice for you.
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  264. Zune and iPod: Most people compare the Zune to the Touch, but after seeing how slim and surprisingly small and light it is, I consider it to be a rather unique hybrid that combines qualities of both the Touch and the Nano. It's very colorful and lovely OLED screen is slightly smaller than the touch screen, but the player itself feels quite a bit smaller and lighter. It weighs about 2/3 as much, and is noticeably smaller in width and height, while being just a hair thicker.
  265. Zune and iPod: Most people compare the Zune to the Touch, but after seeing how slim and surprisingly small and light it is, I consider it to be a rather unique hybrid that combines qualities of both the Touch and the Nano. It's very colorful and lovely OLED screen is slightly smaller than the touch screen, but the player itself feels quite a bit smaller and lighter. It weighs about 2/3 as much, and is noticeably smaller in width and height, while being just a hair thicker.
  266. Zune and iPod: Most people compare the Zune to the Touch, but after seeing how slim and surprisingly small and light it is, I consider it to be a rather unique hybrid that combines qualities of both the Touch and the Nano. It's very colorful and lovely OLED screen is slightly smaller than the touch screen, but the player itself feels quite a bit smaller and lighter. It weighs about 2/3 as much, and is noticeably smaller in width and height, while being just a hair thicker.
  267. Sorry for the huge review, but I'm really loving the new Zune, and hope this, as well as the excellent reviews some other people have written, will help you decide if it's the right choice for you.
  268. Between me and my husband we've owned more MP3 players over the years than I can count, including Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, etc. But, the last few years I've settled down to one line of players. Why? Because I was happy to discover how well-designed and fun to use the underappreciated (and widely mocked) Zunes are.
  269. This is getting a bit more subjective, but I much prefer the Zune Marketplace. The interface is colorful, has more flair, and some cool features like 'Mixview' that let you quickly see related albums, songs, or other users related to what you're listening to. Clicking on one of those will center on that item, and another set of "neighbors" will come into view, allowing you to navigate around exploring by similar artists, songs, or users. Speaking of users, the Zune "Social" is also great fun, letting you find others with shared tastes and becoming friends with them. You then can listen to a playlist created based on an amalgamation of what all your friends are listening to, which is also enjoyable. Those concerned with privacy will be relieved to know you can prevent the public from seeing your personal listening habits if you so choose.
  270. Between me and my husband we've owned more MP3 players over the years than I can count, including Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, etc. But, the last few years I've settled down to one line of players. Why? Because I was happy to discover how well-designed and fun to use the underappreciated (and widely mocked) Zunes are.
  271. The new Zune browser is surprisingly good, but not as good as the iPod's. It works well, but isn't as fast as Safari, and has a clunkier interface. If you occasionally plan on using the web browser that's not an issue, but if you're planning to browse the web alot from your PMP then the iPod's larger screen and better browser may be important.
  272. Apple now has Rhapsody as an app, which is a great start, but it is currently hampered by the inability to store locally on your iPod, and has a dismal 64kbps bit rate. If this changes, then it will somewhat negate this advantage for the Zune, but the 10 songs per month will still be a big plus in Zune Pass' favor.
  273. Between me and my husband we've owned more MP3 players over the years than I can count, including Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, etc. But, the last few years I've settled down to one line of players. Why? Because I was happy to discover how well-designed and fun to use the underappreciated (and widely mocked) Zunes are.
  274. I'll gear this review to 2 types of people: current Zune owners who are considering an upgrade, and people trying to decide between a Zune and an iPod. (There are other players worth considering out there, like the Sony Walkman X, but I hope this gives you enough info to make an informed decision of the Zune vs players other than the iPod line as well.)
  275. The Zune concentrates on being a Portable Media Player. Not a web browser. Not a game machine. Maybe in the future it'll do even better in those areas, but for now it's a fantastic way to organize and listen to your music and videos, and is without peer in that regard. The iPod's strengths are its web browsing and apps. If those sound more compelling, perhaps it is your best choice.
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  277. The new Zune browser is surprisingly good, but not as good as the iPod's. It works well, but isn't as fast as Safari, and has a clunkier interface. If you occasionally plan on using the web browser that's not an issue, but if you're planning to browse the web alot from your PMP then the iPod's larger screen and better browser may be important.
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  279. Zune and iPod: Most people compare the Zune to the Touch, but after seeing how slim and surprisingly small and light it is, I consider it to be a rather unique hybrid that combines qualities of both the Touch and the Nano. It's very colorful and lovely OLED screen is slightly smaller than the touch screen, but the player itself feels quite a bit smaller and lighter. It weighs about 2/3 as much, and is noticeably smaller in width and height, while being just a hair thicker.
  280. Sorry for the huge review, but I'm really loving the new Zune, and hope this, as well as the excellent reviews some other people have written, will help you decide if it's the right choice for you.
  281. If you're still on the fence: grab your favorite earphones, head down to a Best Buy and ask to plug them into a Zune then an iPod and see which one sounds better to you, and which interface makes you smile more. Then you'll know which is right for you.
  282. If you're still on the fence: grab your favorite earphones, head down to a Best Buy and ask to plug them into a Zune then an iPod and see which one sounds better to you, and which interface makes you smile more. Then you'll know which is right for you.
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  305. Zune and iPod: Most people compare the Zune to the Touch, but after seeing how slim and surprisingly small and light it is, I consider it to be a rather unique hybrid that combines qualities of both the Touch and the Nano. It's very colorful and lovely OLED screen is slightly smaller than the touch screen, but the player itself feels quite a bit smaller and lighter. It weighs about 2/3 as much, and is noticeably smaller in width and height, while being just a hair thicker.
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  323. Zune and iPod: Most people compare the Zune to the Touch, but after seeing how slim and surprisingly small and light it is, I consider it to be a rather unique hybrid that combines qualities of both the Touch and the Nano. It's very colorful and lovely OLED screen is slightly smaller than the touch screen, but the player itself feels quite a bit smaller and lighter. It weighs about 2/3 as much, and is noticeably smaller in width and height, while being just a hair thicker.
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