Durham v. Butler, 89 So. 3d 1023

Rebekah Durham appeals a Florida circuit court order denying dismissal of Robert Butler's paternity complaint.
Mother argues Florida court lacked jurisdiction because a Missouri proceeding had not been resolved.
Missouri originally issued a 2002 decree for paternity, child support, and visitation; confirmation order followed years later.
Parties moved to Florida; father filed paternity action in Miami-Dade in June 2011; Missouri proceeding remained pending with an appeal filed in 2011.
Florida denied the motion to dismiss; court treated the appeal as a petition for writ of prohibition seeking to halt Florida jurisdiction.
Court held that under UCCJEA, Florida should not exercise jurisdiction while Missouri proceeding is pending.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Florida lacked jurisdiction under UCCJEA because a related Missouri proceeding is pending	Durham: Missouri case pending bars Florida jurisdiction	Butler: Florida may exercise jurisdiction to modify if appropriate	Florida court should not exercise jurisdiction; writ of prohibition granted
Whether a writ of prohibition is an appropriate remedy	Prohibition is the proper remedy to prevent improper jurisdiction	Remedy may be unnecessary if jurisdiction is proper	Writ of prohibition is appropriate in this jurisdictional context

Karam v. Karam, 6 So.3d 87 (Fla. 3d DCA 2009) (UCCJEA controls custody disputes; substantial conformity bars Florida jurisdiction)
London v. London, 32 So.3d 107 (Fla. 2d DCA 2009) (home-state and jurisdictional issues; maintains limitations on Florida modification)
Custody of a Minor, 392 Mass. 728 (Mass. 1984) (simultaneous proceedings doctrine; pending appeal precludes jurisdiction)
In re Custody of Rector, 565 P.2d 950 (Colo. App. 1977) (pending appeal precludes concurrent proceedings under UCCJA framework)
Mandico v. Taos Constr., Inc., 605 So.2d 850 (Fla. 1992) (prohibition as remedy when court acts beyond jurisdiction)