## Facts

- Glenn Pappas and Nan O’Brien divorced in California after six years of marriage and the birth of two sons, A.P. and P.P.
- The California divorce order granted the parents joint legal custody, awarded O’Brien primary physical custody, and required Pappas to pay child support.
- Pappas later moved to Oklahoma. O’Brien and the children moved to Georgia, where O’Brien registered the California divorce and custody decree.
- In Georgia, O’Brien filed to increase child support. The Georgia court granted the request and stated that Pappas’s child-support obligation would cease if custody was later changed by a court with authority to do so.
- Two years later, P.P. moved to Oklahoma to live with Pappas. Pappas filed an Oklahoma petition seeking physical custody of P.P. and termination of child-support payments for A.P., who had reached the age of majority.
- After a hearing, the Oklahoma court awarded Pappas custody of P.P., retroactively relieved Pappas of his child-support obligation, and ordered O’Brien to pay retroactive and ongoing child support to Pappas for P.P.’s benefit.
- P.P. later returned to live with O’Brien in Georgia. Pappas pursued support for the period when P.P. lived with him, and an administrative law judge issued an order awarding Pappas retroactive child support.
- O’Brien moved to Vermont. Acting for Pappas, Vermont’s Office of Child Support (OCS) filed in Vermont to register the Oklahoma support order under the Uniform Interstate Family Support Act (UIFSA).
- O’Brien moved to set aside the registered Oklahoma order. The Vermont court registered the Oklahoma order, and O’Brien appealed. The appellate court affirmed.
- O’Brien then filed documents in Vermont seeking to stay enforcement and to register the Georgia child-support order. OCS moved to dismiss O’Brien’s action. The Vermont court granted the motion, and O’Brien appealed.
- The Vermont Supreme Court consolidated the two appeals.

## Issues

1. Whether Vermont properly registered and enforced the Oklahoma support order under UIFSA despite O’Brien’s attempt to set it aside.
2. Whether O’Brien could use Vermont proceedings to relitigate challenges to the validity or enforceability of the Oklahoma support order after Oklahoma proceedings had resolved custody and support.
3. Whether Vermont properly dismissed O’Brien’s attempt to register and proceed on the Georgia child-support order after the Oklahoma proceedings and resulting support order.

## Decision

- The Vermont Supreme Court consolidated O’Brien’s appeals arising from (1) registration/enforcement of the Oklahoma order and (2) dismissal of O’Brien’s Vermont filing aimed at the Georgia order.
- The Court upheld Vermont’s registration and enforcement of the Oklahoma child-support order under UIFSA.
- The Court rejected O’Brien’s effort to set aside the Oklahoma order through the Vermont registration proceeding.
- The Court affirmed dismissal of O’Brien’s attempt to proceed in Vermont on the Georgia child-support order.

## Legal Principles

- UIFSA provides a mechanism for a responding state to register and enforce a child-support order issued by another state.
- In a UIFSA registration proceeding, the responding tribunal enforces a registered support order and does not conduct a second merits hearing on the issuing state’s support determination.
- Final rulings made in the issuing state’s proceedings may bar later attempts to relitigate the same matters in another forum, consistent with preclusion principles and interstate enforcement requirements.
- When multiple interstate proceedings or orders exist, UIFSA’s framework favors recognition and enforcement of the order that is entitled to effect under UIFSA and related full-faith-and-credit principles, rather than parallel enforcement of competing orders.

## Conclusion

OCS/Pappas v. O’Brien holds that Vermont properly registered and enforced the Oklahoma child-support order under UIFSA and that O’Brien could not undo that result by attempting to reopen Oklahoma-determined custody/support outcomes or by initiating a separate Vermont effort to register and proceed on the earlier Georgia support order.


OCS/Pappas v. O'Brien, 67 A.3d 916 (2013)