Katkin v. Komorebi CA6, H050891

Amadasophia Komorebi (Mother) and Andrew Katkin (Father) are parents to A.K., born in Massachusetts, where Mother raised her for the first 17 months.
In December 2020, Mother brought A.K. to California to meet Father; during this period, Mother applied for California public assistance and child support.
In February 2021, Father filed for emergency custody, citing concerns over A.K.’s health and the possibility Mother would remove her from California; the trial court granted him temporary physical custody.
The court conducted further hearings, found Mother lacking in credibility, and ultimately awarded Father permanent sole legal and physical custody, allowing Mother only remote visitation.
Mother appealed, arguing lack of California jurisdiction under the UCCJEA, due process violations, and other procedural/substantive grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction under UCCJEA	Mother: Massachusetts was A.K.’s home state, so CA lacked jurisdiction.	Father: A.K. no longer had a home state; significant connection to CA.	Trial court had significant connection jurisdiction under the UCCJEA; affirmed.
Due Process in Emergency Custody	Mother: Custody change was without fair hearing.	Father: Proper hearing and opportunities were provided.	Due process satisfied through hearings and notice.
Full Faith and Credit	Mother: CA failed to honor MA’s custody authority.	Father: No MA order was disregarded; no evidence of CA’s mistrust.	Argument forfeited/not supported; MA orders were honored.
Best Interests and Parental Fitness	Mother: Court ignored alleged unfitness of Father and A.K.’s best interests.	Father: Court considered all evidence, including Mother’s abduction of A.K.	Court’s best interests findings supported by record; custody to Father affirmed.

Kumar v. Superior Court, 32 Cal.3d 689 (Cal. 1982) (discusses avoidance of jurisdictional competition under UCCJEA)
In re Caden C., 11 Cal.5th 614 (Cal. 2021) (substantial evidence standard for review of family law decisions)
People v. Stanley, 10 Cal.4th 764 (Cal. 1995) (forfeiture of points not raised with legal argument and authority)