In Re Interests A.A.-F., 444 P.3d 938

Five of Mother’s six children were subject to child in need of care (CINC) proceedings originally in California; California transferred those proceedings to Geary County, Kansas, in June 2015 under the UCCJEA.
Mother and one father had moved to Kansas; the children were transported to Kansas after the California transfer order. Mother did not appeal the California transfer.
Kansas DCF implemented a reintegration plan; the district court later found reintegration with Mother was no longer viable and ultimately found Mother unfit and terminated parental rights in early 2017.
Mother challenged Kansas subject-matter jurisdiction (arguing the California transfer was procedurally deficient) and alleged a due process violation for the district court’s failure to hold a statutorily required permanency hearing within 30 days of the reintegration determination.
The Court of Appeals affirmed (divided panel); the Kansas Supreme Court granted review and affirmed the district court, holding Kansas did not abuse its discretion in accepting jurisdiction and Mother’s due process claim failed.

Issue	Plaintiff's Argument (Mother)	Defendant's Argument (State/Kansas)	Held
Whether Kansas had subject-matter jurisdiction after California’s transfer under the UCCJEA	The California transfer was procedurally defective (no adequate findings, Mother lacked meaningful opportunity to contest transfer), so Kansas lacked jurisdiction	California’s transfer order prima facie established jurisdiction; comity/full‑faith respect applies; Mother failed to provide record to rebut presumption	Kansas did not abuse discretion in exercising jurisdiction; transfer was consistent with UCCJEA and Mother failed to rebut presumption of valid transfer
Whether Mother’s due process rights were violated by delay in holding a permanency hearing within 30 days after reintegration was deemed not viable	Statutory 30‑day permanency hearing requirement was not followed, depriving Mother of a meaningful, timely opportunity to be heard before termination proceedings	Mother received notice and multiple opportunities to be heard; evidentiary hearing occurred; delay did not create substantial risk of erroneous deprivation	No constitutional due process violation shown; minimal process requirements met and Mother failed to show prejudice

State v. Dunn, 304 Kan. 773 (discusses standard of review for questions of law)
State v. Dupree, 304 Kan. 43 (statutory sources of jurisdiction)
Merriman v. Crompton Corp., 282 Kan. 433 (party invoking jurisdiction bears the burden)
Padron v. Lopez, 289 Kan. 1089 (comity and presumption of validity for sister‑state orders)
In re J.D.C., 284 Kan. 155 (Mathews balancing for procedural due process)
In re A.A., 51 Kan. App. 2d 794 (contrast case: limits on presuming transfer findings)
Mathews v. Eldridge, 424 U.S. 319 (framework for due process balancing)