In Arkansas Department of Human Services v. Cox, 349 Ark. 205, 82 S.W.3d 806, 812-13 (Ark. 2002), the Arkansas Department of Human Services (DHS), under the authority of a Florida court order, seized a child born in Arkansas and, in disobedience of a subsequent Arkansas court order to return the child to her grandmother, delivered the child to Florida authorities.
DHS argued the Arkansas court should have given full faith and credit to the Florida order to pick up the child. Id. at 808.
The Arkansas Supreme Court disagreed, concluding that Florida did not have jurisdiction in substantial conformity with the UCCJEA because the UCCJEA did not apply to unborn children. Id. at 812-13 (citing UCCJEA's definition of "child").