Background
Preston C. and Zakariya S., both 24 years old, were in a dating relationship and had a child (W.C.) born in December 2020 in Centralia, Illinois. The family moved to Iowa in October 2021 and lived together there until the parties’ relationship ended in March 2023. Preston returned to Illinois; Zakariya remained in Iowa. The parties implemented a shared custody arrangement where W.C. initially alternated between each parent every two weeks. Beginning in October 2024, W.C. resided primarily with Zakariya in Iowa but spent periodic time with Preston in Illinois—approximately 50 days with Preston and 132 days with Zakariya during the six months preceding the filing of this action.
On April 9, 2025, Preston filed a petition to establish parentage in Marion County, Illinois, seeking parental responsibility, majority parenting time, and child support. On July 9, 2025, Zakariya moved to dismiss for lack of jurisdiction under the Uniform Child-Custody Jurisdiction and Enforcement Act (UCCJEA), arguing that Iowa was the proper forum. The trial court held a two-day hearing and denied Zakariya’s motion on November 20, 2025. Zakariya appealed, raising four issues regarding jurisdiction under the UCCJEA.
The Court’s Holding
The appellate court affirmed, holding that Illinois had jurisdiction over the parentage and custody matter. The court first determined that W.C. had no “home state” under the UCCJEA because he had not resided with either parent in either state for six consecutive months immediately preceding the filing of Preston’s petition. Although Zakariya argued that Iowa was W.C.’s home state, the evidence showed W.C. spent time in both states during the relevant six-month period, residing with neither parent for the required consecutive six months.
Because neither state qualified as the child’s home state, the court applied the “significant connections” test under UCCJEA § 201(a)(2). The court found that Preston and W.C. had significant connections to Illinois through family ties (Preston’s extended family held regular Sunday cookouts and family gatherings), participation in sports (T-ball in Illinois), and medical care (pediatrician Dr. Stedelin in Illinois). The court also found that substantial evidence and witnesses were available in Illinois to resolve the dispute. The trial court did not abuse its discretion in declining to apply the inconvenient forum doctrine, particularly given the inconsistencies in Zakariya’s testimony regarding the parties’ custody arrangements and her stated intent to relocate to Des Moines, Iowa.
Key Takeaways
- When a child lacks a single “home state” due to shared custody arrangements, courts may exercise jurisdiction based on “significant connections” between the child and state parties, not just residence duration.
- Evidence of community involvement—such as participation in sports leagues, regular family gatherings, and established medical providers—supports a finding of significant connections for UCCJEA jurisdiction.
- Witness availability and location of evidence within a state are relevant factors in determining whether a court should exercise jurisdiction under the “significant connections” test.
- Credibility determinations regarding parental testimony about custody arrangements and agreements can be dispositive in forum selection disputes.
- The inconvenient forum doctrine (§ 207(b) factors) requires consideration of domestic violence allegations, distance, financial hardship, and witness location, but does not automatically transfer jurisdiction to another state with equal connections.
Why It Matters
This decision clarifies how Illinois courts apply the UCCJEA when interstate custody disputes involve shared parenting arrangements that prevent identification of a traditional “home state.” The ruling is significant for practitioners handling custody and parentage matters in multi-state contexts, as it establishes that jurisdiction can be properly exercised when a child has developed significant connections to a state through family, medical, educational, and community ties—even when the child spends equal or substantial time in another state. The decision reflects the UCCJEA’s policy goal of promoting cooperation between states while preventing custody litigation from ping-ponging between jurisdictions.
For practitioners, the case underscores the importance of building a comprehensive factual record regarding community connections beyond mere residence duration. Courts will examine the nature and stability of family relationships, the establishment of medical relationships, participation in organized activities, and social connections within a state. Additionally, the court’s attention to witness credibility and the locations where witnesses and evidence reside emphasizes that evidentiary considerations remain central to forum selection analysis, and that a parent’s intent to relocate may factor into the analysis of significant connections and inconvenience to the non-relocating parent.