Interstate child custody dispute; The Uniform Child-Custody Jurisdiction & Enforcement Act (UCCJEA); Subject-matter jurisdiction; Reliance on the Child Custody Act (CCA), Acknowledgment of Parentage Act, & Paternity Act; Applicability of MCR 2.621; The collateral bar rule; In re Ferranti; Standing; Enforcement of an Arizona custody order; MCL 722.1307; MCL 722.1304(4); “Shall”; The Parental Kidnapping Prevention Act; US Const, art IV, § 1; 28 USC § 1738

Concluding that respondent-mother’s (Brock) jurisdictional arguments lacked merit, the court held that the trial court complied with the UCCJEA’s mandates and did not err in “registering, confirming, and enforcing the Arizona custody order” obtained by petitioner-father (Winter). It first noted that Brock’s reliance on the CCA, the Acknowledgment of Parentage Act, and the Paternity Act was misplaced. Given that this was “an interstate custody dispute, ‘[t]he UCCJEA is the exclusive basis for determining whether a court has jurisdiction to make an initial child-custody determination.’” Her reliance on MCR 2.621 was also misplaced as it did not apply. She next argued that the trial court erred in “registering and confirming the Arizona custody order because the Arizona trial court lacked subject-matter jurisdiction over the custody proceedings[.]” The court determined this was an impermissible collateral attack on its 10/23 order in a related prior case, which “held that Arizona was the child’s home state under the UCCJEA and ordered the dismissal of a custody action initiated by Brock for lack of jurisdiction.” It noted that she “had an opportunity to ‘seek relief by’ filing a motion for reconsideration of [that] order, or by filing an application for leave to appeal to our Supreme Court.” While she unsuccessfully moved for reconsideration, “she did not avail herself of the opportunity to seek leave to appeal to our Supreme Court, and the time to do so has long since expired.” Thus, she failed to “exercise her direct right to appeal to the Supreme Court.” She tried to avoid the collateral bar rule by arguing that the court lacked jurisdiction to issue the 10/23 “order because Winter lacked standing to appeal.” But the court concluded it had jurisdiction over the appeal even if Winter lacked standing, “and the alleged lack of standing does not render void the” 10/23 order. As a result, “the collateral bar rule prohibits Brock from arguing that the Arizona trial court lacked subject-matter jurisdiction over the custody matter under the UCCJEA.” In addition, for these reasons, she was “not entitled to relief under MCL 722.1206, MCL 722.1207, and MCL 722.1208.” Further, given that “the Arizona trial court had subject-matter jurisdiction under the UCCJEA, Brock’s arguments that” the US Constitution and federal statutes barred enforcement of the Arizona custody order had no merit. Affirmed.