## Facts

- A Nebraska dissolution decree (1997) ordered the father to pay child support during each child’s minority; Nebraska’s age of majority is 19.
- Later Nebraska modifications allowed the mother to relocate to Washington and adjusted other terms, but did not change the duration of child support.
- The mother and children moved to Washington; the father moved to Minnesota.
- The mother registered the Nebraska decree in Washington and later sought modification in Washington to obtain postsecondary educational support for the older child while she prepared to attend college.
- The father sought a downward modification of support for the younger child and, by doing so, submitted to personal jurisdiction in Washington for UIFSA purposes.
- The Washington trial court granted postsecondary educational support for the older child under Washington law, extending support up to age 23, and denied the father’s requested downward modification.
- The Court of Appeals affirmed; the Washington Supreme Court granted review.

## Issues

1. Whether UIFSA permits a Washington court modifying a Nebraska child-support order to extend the duration of support beyond what Nebraska law allows by awarding postsecondary educational support under Washington law.
2. Whether postsecondary educational support is a separate, new obligation or part of the “duration” of the existing child-support obligation governed by the issuing state’s law under UIFSA.

## Decision

- The Washington Supreme Court reversed the Court of Appeals and remanded.
- The court held that UIFSA requires the issuing state’s law (Nebraska) to govern the duration of the child-support obligation.
- Because Nebraska law would not have authorized the postsecondary educational support ordered here, Washington lacked authority to extend support beyond Nebraska’s age of majority.

## Legal Principles

- Under UIFSA, the issuing state’s law controls the duration of a child-support obligation, even after registration and modification in another state.
- A forum state with UIFSA modification jurisdiction may adjust certain terms of support, but may not extend the obligation beyond the issuing state’s maximum duration.
- Postsecondary educational support that extends payments beyond the issuing state’s age of majority constitutes an extension of “duration” subject to UIFSA’s issuing-state choice-of-law rule.

## Conclusion

The court held that UIFSA bars Washington from extending the duration of a Nebraska child-support obligation through a postsecondary educational support award when Nebraska law would not allow such an extension, and it reversed and remanded for proceedings consistent with that limitation.


In re Schneider, 173 Wash. 2d 353, 268 P.3d 215 (Wash. 2011)