## Facts

- A child was born in Iowa in February 1991; the mother initially identified another man as the father and signed a relinquishment.
- The child was placed with a Michigan couple, who received temporary custody while an Iowa adoption petition was pending.
- The mother later sought to revoke her relinquishment and asserted that a different man was the biological father.
- Iowa courts adjudicated the biological father’s paternity, refused to terminate his parental rights, denied the adoption, and entered orders requiring the Michigan couple to return the child.
- After failing to comply with Iowa’s custody directives, the Michigan couple filed actions in Michigan seeking jurisdiction under the UCCJA, an injunction against enforcement of Iowa’s judgment, and a custody decision based on the child’s best interests.
- A Michigan trial court issued interim relief keeping the child in Michigan and proceeded on a best-interests approach; the Michigan Court of Appeals reversed and ordered enforcement of the Iowa judgment.
- The Michigan Supreme Court granted review and consolidated the related matters.

## Issues

1. Whether Michigan courts could assume jurisdiction under the UCCJA and refuse to enforce or effectively modify Iowa’s custody/adoption orders, or instead had to recognize and enforce them under full faith and credit principles and the UCCJA.
2. Whether a Michigan court could conduct a de novo best-interests custody determination that would defeat a fit biological parent’s rights and conflict with a valid sister-state judgment.

## Decision

- The Michigan Supreme Court reversed the Michigan trial court and affirmed the Court of Appeals.
- The Court held Iowa properly exercised jurisdiction as the child’s home state and had already entered controlling determinations regarding paternity, termination of parental rights, and custody.
- Michigan lacked authority to relitigate custody through a new best-interests inquiry inconsistent with Iowa’s adjudications.
- Michigan courts were directed to recognize and enforce the Iowa orders, resulting in transfer of custody to the biological father pursuant to those orders.

## Legal Principles

- Under the UCCJA, when another state has properly exercised jurisdiction—particularly as the child’s home state—a non-home-state court generally must decline conflicting jurisdiction and may not modify the sister state’s custody determination absent narrow statutory grounds.
- Full faith and credit principles bar a state from functionally relitigating issues already resolved by a final sister-state judgment in custody-related proceedings.
- A best-interests analysis presupposes a lawful contest among parties with valid legal claims; it cannot be used to create custodial rights in third parties that displace a fit biological parent whose rights were not lawfully terminated.
- Third-party custodians who obtained temporary custody through state processes contingent on adoption do not gain a superior claim to custody merely through the passage of time or the child’s attachment.

## Conclusion

The Michigan Supreme Court required enforcement of Iowa’s custody/adoption orders, holding that Michigan could not use a best-interests inquiry to override a fit biological parent’s unextinguished rights or to contradict Iowa’s properly exercised jurisdiction and binding judgments.


In re Clausen, 442 Mich. 648, 502 N.W.2d 649 (Mich. 1993)