Raymond C. Tisdale v. Christine M. (Tisdale) Bolick, 2012 Ind. App. LEXIS 550

Dissolution decree for Raymond Tisdale and Christine Bolick entered August 25, 2003; Mother was awarded sole legal and physical custody.
Mother filed in November 2009 to transfer custody and parenting time issues to South Carolina for inconvenient forum; petition referenced custody and relocation, not child support.
Trial court granted transfer of custody/parenting time to Dorchester County, South Carolina, with no explicit reference to child support issues.
In October 2011, Father sought modification of child support; the trial court later held it had no jurisdiction over the case and directed him to file in the correct county.
Father argued the transfer of custody/parenting time did not transfer or extinguish Indiana’s jurisdiction over child support under UIFSA; trial court did not hold a hearing on residency or consent.
This appeal seeks to determine whether Indiana retains continuing, exclusive jurisdiction over child support under UIFSA despite transfer of custody/parenting time under UCCJA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court retained jurisdiction over child support under UIFSA after transferring custody.	Tisdale (Father) argues UIFSA keeps Indiana jurisdiction since order originated there and transfer did not consent to SC modification.	Bolick (Mother) argues transfer of custody/parenting time to SC ends Indiana involvement and thus not applicable to support.	Indiana retains jurisdiction unless consent or relocation changes jurisdiction under UIFSA.
Whether the UCCJA transfer of custody/custody-related issues affects the ability to modify child support.	Father contends UCCJA transfer is incidental and does not extinguish support jurisdiction.	Mother contends remedies are governed by UIFSA unrelated to custody transfer.	UIFSA governs support; UCCJA transfer does not automatically end Indiana support jurisdiction absent consent or modification.
Was there prima facie error in the trial court’s summary denial of the petition to modify child support without an evidentiary hearing on residency/consent?	Father established prima facie error by lack of hearing on residency/consent; order should be remanded for UIFSA jurisdiction determination.	Mother implied the court properly declined to exercise exclusive jurisdiction pending other proceedings.	Prima facie error established; reversed and remanded for a hearing on continuing, exclusive jurisdiction under UIFSA.

Mikel v. Johnston, 907 N.E.2d 547 (Ind. Ct. App. 2009) (prima facie rule for appellee failure; apply law to record)