In Re LS, 257 P.3d 201

Parenting dispute over custody of child born 2001; child resides in Colorado with mother, father resides in Nebraska.
Father filed Nebraska custody action; Nebraska court initially awarded custody to father and later final decree awarded custody to father.
Colorado mother filed a Colorado custody action; Colorado court awarded custody to mother and did not enforce Nebraska decree.
Nebraska order was challenged under PKPA/UCCJEA; Colorado Court of Appeals held Nebraska lacked jurisdiction but Nebraska decree entitled to full faith and credit.
Colorado Supreme Court reversed, holding Nebraska did not have jurisdiction under PKPA/UCCJEA, so Colorado need not enforce Nebraska decree.
Warrant issued by Nebraska for return of child; mother continued to reside in Colorado and did not comply with Nebraska order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Nebraska act in compliance with PKPA to exercise custody jurisdiction?	Spotanski: Nebraska complied with PKPA requirements.	McNamara: Nebraska failed PKPA requirements.	Nebraska did not comply with PKPA.
Must Colorado enforce Nebraska's custody decree if Nebraska lacked PKPA-compliant jurisdiction?	Spotanski: yes, enforceable under PKPA/UCCJEA.	McNamara: no, no full faith and credit from PKPA.	Colorado not required to enforce Nebraska decree.
Which state was the child's home state for initial jurisdiction purposes?	Spotanski: Nebraska home state; jurisdiction proper there.	McNamara: Colorado home state; Nebraska declined to exercise.	Colorado was the child's home state; Nebraska lacked jurisdiction.

Thompson v. Thompson, 484 U.S. 174 (1988) (PKPA aims for nationwide enforcement of custody orders)
Durfee v. Duke, 375 U.S. 106 (1963) (full faith and credit in interstate custody disputes)
A.J.C., 88 P.3d 599 (Colo. 2004) (Colorado recognizes PKPA governs enforcement)
In re Baby Girl Clausen, 442 Mich. 648 (1993) (PKPA enforcement considerations in interstate custody)