## Facts

- Keith W. Glanzer (father) and Suzanne E. Glanzer (mother) married in Illinois in 1981; their son, Bradley, was born in Missouri in 1982.
- The family lived in multiple states due to military assignments; relevantly, Bradley lived in Missouri from January 1985 until October 29, 1985, when mother and child moved to California.
- On December 18, 1985, mother filed in California for separation and custody; father was personally served in January 1986 and challenged California’s custody jurisdiction.
- On January 10, 1986, father filed in Missouri for dissolution and custody; mother contested Missouri jurisdiction based on the pending California matter.
- California exercised custody jurisdiction under a “significant connections” theory and awarded custody to mother with visitation for father.
- Missouri later entered a dissolution decree awarding custody to father with visitation for mother, rejecting the argument that California’s custody ruling controlled.
- After continued conflict and while the child was in Missouri visiting paternal grandparents, the child was not returned to mother; mother filed a Missouri habeas corpus petition seeking return of the child based on the California decree.
- The appellate court initially issued a temporary writ returning the child to mother pending resolution.
- In a consolidated matter, the Division of Child Support Enforcement issued an administrative order finding father owed $11,118 in child and spousal support arrearages; a trial court reversed that administrative outcome, and the Division appealed.

## Issues

1. Under the Parental Kidnapping Prevention Act (PKPA), whether California’s custody decree was entitled to interstate enforcement or whether Missouri, as the child’s “home state,” had priority such that its custody decree controlled.
2. Whether mother was entitled to habeas corpus relief in Missouri compelling return of the child based on the California custody decree.
3. In the consolidated support appeal, whether the administrative arrearage determination was enforceable as to child support and/or spousal support.

## Decision

- The court held Missouri was the child’s PKPA “home state” at the time the custody dispute commenced because the child had lived in Missouri within six months before mother filed in California.
- The California custody decree was not entitled to interstate enforcement against Missouri under the PKPA; Missouri’s custody decree controlled in Missouri.
- Mother’s petition for a writ of habeas corpus was denied, and the court quashed its earlier temporary writ.
- On the consolidated appeal, the court affirmed the arrearage determination as to child support and reversed as to spousal support.

## Legal Principles

- Under the PKPA, interstate enforceability of a custody decree turns on compliance with federal jurisdictional prerequisites, including priority for the child’s “home state.”
- A custody decree entered by a non-home-state court under a “significant connections” rationale may be denied interstate enforcement when another state qualifies as the PKPA home state.
- Habeas corpus relief premised on enforcement of an out-of-state custody decree may be denied when that decree lacks PKPA entitlement to interstate enforcement and an in-state decree controls.
- Child support and spousal support arrearages may be treated separately on review; an enforcement order may be affirmed in part and reversed in part based on authority and record support.

## Conclusion

The court refused to enforce California’s custody decree because Missouri was the child’s PKPA home state, denied habeas relief seeking the child’s return under the California order, and, in the consolidated matter, upheld the child support arrearage while setting aside the spousal support arrearage.


Glanzer v. State, Dep’t of Soc. Servs., Div. of Child Support Enf’t (In re Custody of Bradley Carl Glanzer), 835 S.W.2d 386 (Mo. Ct. App. 1992)