Background - Father (U.S. citizen) and Mother (Italian citizen) married in Italy; child born in Italy; Italian court awarded child and spousal support (€1,000 child, €400 spousal) and custody to Mother. - Sacramento County Dept. of Child Support Services registered the Italian support order in California under UIFSA, attaching the Italian judgment and English translation. - Father timely requested a hearing to contest registration, arguing Italy is not a "state" under UIFSA (so registration/enforcement was unauthorized) and submitted briefs comparing Italian versus California support laws. - The trial court held Father bore the burden to prove Italy was not a "state," denied an evidentiary hearing and a statement of decision (Father’s request for the latter was untimely), and confirmed registration. - Father appealed; the Court of Appeal affirmed, holding Father had the burden under Fam. Code § 4956(a), failed to prove Italy was not a UIFSA "state," and that no statement of decision was required. ### Issues | Issue | Father’s Argument | Department’s Argument | Held | |---|---:|---|---| | Who bears burden to prove a foreign country is not a "state" under UIFSA? | Burden on Department (moving party) to show Italy is a UIFSA "state." | Burden on contesting party under § 4956(a) to prove a permitted defense to registration. | Held: Father (contesting party) bore burden to prove Italy is not a state under UIFSA. | | Whether Italy qualifies as a "state" under UIFSA (i.e., has laws/procedures substantially similar for issuance/enforcement)? | Italy’s substantive support laws differ materially from California’s; therefore it cannot be a UIFSA "state." | UIFSA requires similarity in procedures for issuance/enforcement (recognition/enforcement of U.S. orders), not identity of substantive support formulas. | Held: Father failed to prove Italy was not a UIFSA state; differences in substantive law do not defeat UIFSA-state status. | | Whether Father was denied opportunity to present evidence/evidentiary hearing | Father says he sought an evidentiary hearing and was prevented from presenting proof. | Record shows no timely request for an evidentiary hearing; Father’s filings after the hearing do not prove pre-hearing request. | Held: Record does not support a denial of opportunity to present evidence; no evidence Father requested/was denied an evidentiary hearing. | | Whether a statement of decision was required | Father requested a statement of decision after the hearing. | Request was untimely (trial concluded in one day; request must be before submission or within 10 days as applicable). | Held: Father’s request was untimely; no statement of decision required. | ### Key Cases Cited Conservatorship of John L., 48 Cal.4th 131 (clarifies de novo review for certain legal questions) de Leon v. Jenkins, 143 Cal.App.4th 118 (registrations are governed by UIFSA procedures; objections must fall within § 4956 defenses) County of Los Angeles Child Support Services Dept. v. Superior Court, 243 Cal.App.4th 230 (context on UIFSA adoption and amendments) Ginns v. Savage, 61 Cal.2d 520 (opinions do not serve as authority for propositions not considered) Haker-Volkening v. Haker, 547 S.E.2d 127 (N.C. Ct. App.) (discusses evidentiary showing for foreign jurisdiction but did not decide burden allocation) Rains v. Dep’t of Soc. & Health Servs., 989 P.2d 558 (Wash. Ct. App.) (interprets a different statute’s narrower definition of "state" and is inapposite here)