Dean v. Dean

In Dean v. Dean (1984) 133 Mich.App. 220 348 N.W.2d 725, a married couple's two children were born and resided primarily in Michigan until their parents moved to Texas. (348 N.W.2d at p. 726.) The couple separated, and the children and their mother returned to Michigan, where they lived for approximately two years, with the exception of a month-long visit with their father in Texas. (Ibid.) After the parties initiated divorce actions in their respective states of residence, a Texas court awarded the father custody of the children. (Ibid.) The court in Dean concluded that under these facts, the children lacked a significant connection with Texas under the UCCJA. (348 N.W.2d at p. 727.)