Barker v. Barker, 294 Ga. 572

David and Yvonne Barker were divorced in Georgia in 2005; the decree included child custody and child support orders.
In 2012 David (the former husband) filed in Gwinnett County to enforce visitation (contempt) and to modify child support under the 2005 decree.
The Gwinnett trial court dismissed for lack of personal jurisdiction because Yvonne had moved out of Georgia several years earlier.
Georgia statutory law (OCGA § 9-10-91(6)) permits jurisdiction over a nonresident who was previously subject to a Georgia court order for child custody/support when the action is to modify or enforce that order.
The Supreme Court of Georgia reversed, holding the statute embodies the continuing personal jurisdiction doctrine and is consistent with due-process minimum-contacts principles; the case was remanded for further proceedings.

Issue	Plaintiff's Argument (Barker)	Defendant's Argument (Barker)	Held
Whether Georgia courts may assert personal jurisdiction over a former resident to enforce/modify a prior Georgia divorce decree	Georgia may exercise jurisdiction under OCGA § 9-10-91(6) because the original decree included custody/support and David resides in Georgia	Yvonne: subjecting her to Georgia jurisdiction now is unconstitutional because she lacks current contacts with Georgia	Held: Yes. OCGA § 9-10-91(6) applies; continuing jurisdiction over parties to the original divorce is constitutional and permits modification/enforcement
Whether continuing personal jurisdiction conflicts with due-process minimum-contacts	Continuing jurisdiction relies on the contacts that supported the original Georgia decree	Yvonne: those past contacts are insufficient now to satisfy due process	Held: No conflict — contacts that supported initial jurisdiction continue to support jurisdiction for subsequent proceedings arising from the original action

Michigan Trust Co. v. Ferry, 228 U.S. 346 (recognizes continuing personal jurisdiction where original jurisdiction was proper)
McAleavy v. McAleavy, 440 N.W.2d 566 (continuing jurisdiction over divorce-related modification/enforcement proceedings)
State ex rel. Ravitz v. Fox, 273 S.E.2d 370 (explaining policy and rationale for continuing jurisdiction in domestic relations)
Smith v. Smith, 254 Ga. 450 (Georgia precedent treating modification and contempt proceedings as arising from the original divorce for jurisdictional analysis)
In re Marriage of Rassier, 118 Cal. Rptr. 2d 113 (discussing continuing jurisdiction doctrine and Restatement support)