In a Decision – Morgul v. Kruglov, (an "Unreported Decision") >> the Court Held:
The Appellate Division determined that simply because a Divorce Judgment had been registered in New Jersey, did not automatically gave the Family Part jurisdiction over defendant.
The Act clearly states that if "only one tribunal has issued a child support order, the order of that tribunal controls and shall be recognized." N.J.S.A. 2A:4-30.135(a). If the Family Part had applied this provision, it likely would have determined that one of the New York orders controlled.
In sum, the Family Part failed to assess the parties' interstate child support dispute under UIFSA, which led to the mistakes outlined above. For example, the court may have erred by registering the New York FJOD because the parties were then litigating the issue in New York, and it did not consider defendant's argument that he was deprived of his ability to contest the registration of that decree because he was never served with notice of the registration. The Family Part also misconstrued the import of its decision to register the New York FJOD in two significant ways. First, it stated that the registration automatically made defendant subject to New Jersey's jurisdiction when UIFSA essentially states the opposite. Just as importantly, the court also ruled that once the FJOD was registered in this state, a New Jersey court was free to both enforce and modify it. Again, UIFSA makes clear that an out-of-state order may only be modified if the Act's requirements are met.