Kristina Eileen Codino v. Christopher John Codino, W2025-00630-COA-R3-CV

The parties divorced in Virginia and their decree, as amended, provided alternating parenting time and stated that when the child reached school age he would be enrolled where Father resided if Father remained in Virginia or Minnesota. 1
Mother moved to Tennessee on November 1, 2023, and Father later moved to Minnesota on December 16, 2023. 2
After Father objected to Facetime contact, Mother filed in Tennessee to modify the Virginia decree and enforce it through contempt. 3
Father moved to dismiss, arguing Minnesota was the more convenient forum and that the school-enrollment provision effectively selected Minnesota for jurisdiction. 4
The trial court found Tennessee had modification jurisdiction but dismissed the case as an inconvenient forum and awarded Father attorney fees. 5
Minnesota later registered the Virginia decree, stayed its own proceedings, and concluded Tennessee was the more appropriate forum. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Tennessee an inconvenient forum under the UCCJEA? 7	Mother said factor four did not apply and Tennessee was the better forum.	Father said the school provision favored Minnesota and Tennessee should defer.	Tennessee abused its discretion by dismissing; factor four was inapplicable and Tennessee was favored. 8
Did the court need to communicate with Minnesota before declining jurisdiction? 9	Mother argued communication was required or at least necessary.	Father said no mandatory communication duty existed.	No reversible error; communication was not mandatory. 10
Did the court err by not asserting significant-connection jurisdiction? 11	Mother challenged the failure to assert alternate jurisdiction.	Father relied on home-state jurisdiction and Tennessee's jurisdictional authority.	Issue unnecessary to decide because home-state jurisdiction was undisputed. 12
Did the court fail to address enforcement jurisdiction for contempt? 13	Mother sought enforcement of the Facetime provision separately from modification.	Father sought dismissal of the whole petition.	Yes; remand required separate consideration of enforcement/contempt. 14
Was the attorney-fee award proper? 15	Mother argued fees should fall with dismissal.	Father claimed fees as prevailing party under the UCCJEA.	Fee award reversed with the dismissal. 16

Button v. Waite, 208 S.W.3d 366 (Tenn. 2006) (UCCJEA governs jurisdiction between Tennessee and other states in child-custody cases 17)
Hernandez v. Hernandez, 2019 WL 3430534 (Tenn. Ct. App. 2019) (UCCJEA is codified in Tennessee 18)
Kapustka v. Kapustka, 2016 WL 3250120 (Tenn. Ct. App. 2016) (inconvenient-forum rulings are reviewed for abuse of discretion 19)
Eldridge v. Eldridge, 42 S.W.3d 82 (Tenn. 2001) (abuse of discretion occurs outside the range of reasonable rulings 20)
Lee Med., Inc. v. Beecher, 312 S.W.3d 515 (Tenn. 2010) (discretionary decisions must consider the applicable law and facts 21)
Sykes v. Sykes, 647 S.W.3d 596 (Tenn. Ct. App. 2021) (significant connection jurisdiction is an alternate jurisdictional avenue 22)
Staats v. McKinnon, 206 S.W.3d 532 (Tenn. Ct. App. 2006) (home-state jurisdiction principles and temporary absences 23)
Gutzke v. Gutzke, 908 S.W.2d 198 (Tenn. Ct. App. 1995) (temporary absences do not toll home-state time calculations 24)