In a Decision – D.S. v. Z.S.,, (an "Unreported Decision") >> the Court Held:
The Appellate Division reversed the Decision of the Trial Court because the Trial Court lacked subject matter jurisdiction because mother and father, as well as their daughter, had all resided in New York for over a year..
New Jersey lacked exclusive and continuous jurisdiction and that the case belonged in New York. The Appellate Division noted that once the trial court was divested of jurisdiction, it could only modify its prior determination if it had jurisdiction to make an initial determination, but in the present case, the child's home state had long since shifted to New York.