In re Marriage of Aron

In In re Marriage of Aron (1990) 224 Cal. App. 3d 1086, the court held that a California court may modify a child support order rendered in another state if one of the parties resides in California at the time modification is sought. In re Marriage of Aron was decided under the Revised Uniform Reciprocal Enforcement of Support Act of 1968 (RURESA). (In re Marriage of Aron, supra, 224 Cal. App. 3d at p. 1089.) California and Florida replaced RURESA with the Uniform Interstate Family Support Act (UIFSA), and UIFSA (including Cal. Fam. Code, 4909 and Fla. Stat. 88.2051) now governs the jurisdiction of the courts to modify spousal support orders. (See, e.g., In re Marriage of Newman (2000) 80 Cal. App. 4th 846, 849 95 Cal. Rptr. 2d 691.) The support order at issue in In re Marriage of Aron was a child support order, and UIFSA treats child support orders and spousal support orders differently with respect to continuing exclusive jurisdiction. Unlike a spousal support order, with respect to which the residence of the parties is irrelevant as to whether the issuing court has continuing exclusive jurisdiction, a tribunal of the state issuing a child support order under UIFSA has continuing exclusive jurisdiction over the child support order only for as long as at least one of the parties--the obligor, the obligee, or the child--resides in the issuing state. ( Cal. Fam. Code, 4909, subd. (a); Fla. Stat. 88.2051, subd. (1).) Therefore The Court held that the trial court had the power to modify a child support order because one of the parties resided in California.