A summary of the voluminous interstate litigation is beyond the scope of this Report. Appendix A contains a table of relevant UIFSA cases. Appendix B contains a table of relevant FFCCSOA. It is recommended that counsel review the holding in Letellier v. Letellier, No. 01A01-9903-JV-00157, 1999 Tenn. App. LEXIS 637 (Tenn. Ct. App. Sept. 21, 1999), as the result appears contrary to the intent to make UIFSA and FFCCSOA consistent.

The Court of Appeals held that the FFCCSOA gave the Tennessee court subject matter jurisdiction to modify a D.C. child support order, although the mother was the petitioner and UIFSA would have precluded modification in Tennessee. The Juvenile Court of Davidson County had "jurisdiction over the nonmovant" even though the father was a Virginia resident. The father's motion to dismiss for lack of subject matter jurisdiction was a general appearance constituting a waiver of personal jurisdiction, because a contest of personal jurisdiction was not part of his motion to dismiss. D.C. no longer had continuing exclusive jurisdiction, because the father had relocated in Virginia and the mother and children were living in Tennessee. Where there is a conflict between Federal law (FFCCSOA), and State law (UIFSA), Federal law prevails.

A similar analysis of the different results under FFCCSOA and UIFSA appears in Cavallari v. Martin, 732 A.2d 739 (Vt. 1999). The father's motion to modify the duration of his child support obligation, under a New York order, was granted. UIFSA did not apply retroactively to a modification action, filed before but decided after UIFSA's effective date. The Full Faith and Credit for Child Support Orders Act was applicable, but lacked a prohibition on modifying the "non-modifiable terms" of another State's order.