Hays v. Kaelin, 2014 Ohio 3357

Hays and Kaelin dissolved their Kentucky marriage in 2003; Kentucky court awarded shared custody with Hays as primary custodian during the school year.
In 2012 Kentucky ordered Hays to move L.H. to Ohio; Kaelin remained a Kentucky resident; Kentucky issued related visitation/holiday orders in 2011–2012.
In 2013 Hays filed to register the Kentucky custody orders in Ohio and sought modification of those orders.
The trial court ordered registration if required documents were filed and notified Kaelin she could contest the registration.
Kaelin contested the registration claiming Ohio was the improper or inconvenient forum; a magistrate later found the court lacked jurisdiction to modify, but ordered the Kentucky orders to remain registered.
The trial court ultimately dismissed Hays’s objections and his motion to modify, holding Kentucky retained jurisdiction; Hays appealed the registration decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Ohio court properly registered the Kentucky custody orders	Hays: all registration requirements were met; court should register and confirm.	Kaelin: registration could be contested; Kentucky should maintain jurisdiction.	Registration and confirmation required; court did register and confirm.

Patton v. Patton, 2012-Ohio-5798 (2d Dist. Montgomery No. 25346, 2012-Ohio-5798) (de novo review of registration decision under UCCJEA)
Smoske v. Sicher, 2007-Ohio-5617 (11th Dist. Geauga Nos. 2006-G-2720, 2006-G-2731) (statutory interpretation of UCCJEA registration)
In re J.E., 2012-Ohio-704 (8th Dist. Cuyahoga No. 97116) (UCCJEA custody determinations; discretion in custody decisions)
In re M.T., 2008-Ohio-5174 (2d Dist.) (UCCJEA modification procedures separate from registration)
McGhan v. Vettel, 2009-Ohio-2884 (Sup. Ct.) (R.C. 3127.17 modification procedure for foreign custody orders)
Bonds v. Bonds, 2011-Ohio-5867 (11th Dist. Ashtabula No. 2010-A-0063) (separate modification process under UCCJEA)