uccjea issue in California

2019The standard of review The role of the appellate court, “once the [trial] court has evaluated witnesses’ credibility, resolved conflicts in the evidence and made its findings, is to ensure that the provisions of the UCCJEA have been properly interpreted and that substantial evidence supports the factual basis for the [trial] court’s determination whether California may properly exercise subject matter jurisdiction in the case.” (In re Aiden L. (2017) 16 Cal.App.5th 508, 520 .) Accordingly, we review matters of statutory construction de novo, and review the trial court’s factual findings for su

2018The standard of review The role of the appellate court, "once the [trial] court has evaluated witnesses' credibility, resolved conflicts in the evidence and made its findings, is to ensure that the provisions of the UCCJEA *176 have been properly interpreted and that substantial evidence supports the factual basis for the [trial] court's determination whether California may properly exercise subject matter jurisdiction in the case." ( In re Aiden L. (2017) 16 Cal.App.5th 508 , 520, 224 Cal.Rptr.3d 400 .) Accordingly, we review matters of statutory construction de novo, and review the trial cou

2025(Brewer, supra, 218 Cal.App.4th at p. 1320 .) The family court stated in its modification to father’s proposed settled statement that it weighed and discussed each of the section 3427 factors with the parties, solicited argument or comment from them on each factor, and considered each factor in reaching its decision.

2023Although the discretion to excuse forfeiture “must be exercised with special care” in dependency proceedings, because they “involve the well-being of children” and “considerations such as permanency and stability are of paramount importance” (In re S.B., supra, 32 Cal.4th at p. 1293), where a juvenile court may have committed legal error on an issue of vital importance affecting the placement of a child, it may warrant relaxing the rule of forfeiture (In re Alexandria P. (2014) 228 Cal.App.4th 1322, 1348 ).

2023As our Supreme Court has observed in another context, where a statute protects the 12 interests of other sovereigns that are separate and distinct from the interests of parents, “‘the parents’ inaction does not constitute a waiver or otherwise preclude appellate review.’” (In re Isaiah W. (2016) 1 Cal.5th 1, 13 .) Moreover, holding the UCCJEA issue forfeited under these circumstances would be inconsistent with the “‘“the context of the statute as a whole and the overall statutory scheme . . . .”’” (In re Isaiah W., supra, 1 Cal.5th at p. 13 .) Section 3421 delineates four bases for the exercis

2023As our Supreme Court has observed in another context, where a statute protects the 12 interests of other sovereigns that are separate and distinct from the interests of parents, “‘the parents’ inaction does not constitute a waiver or otherwise preclude appellate review.’” (In re Isaiah W. (2016) 1 Cal.5th 1, 13 .) Moreover, holding the UCCJEA issue forfeited under these circumstances would be inconsistent with the “‘“the context of the statute as a whole and the overall statutory scheme . . . .”’” (In re Isaiah W., supra, 1 Cal.5th at p. 13 .) Section 3421 delineates four bases for the exercis

2023(Id. at pp. 353, 355.) In addressing the question 10 of forfeiture, the court of appeal reasoned that: “The UCCJEA . . . embodies an agreement among states on rules to determine which jurisdiction should provide the proper forum. [Citations.] Because it is a mandatory rule, a court errs when it does not satisfy the requirements of the UCCJEA, and a preserved error can lead to reversal. [Citations.] But where, as here, the UCCJEA is not raised in the juvenile court, it can be forfeited just like other important, mandatory rules. [Citation.]” (Id. at p. 358, citing Kabran v. Sharp Memorial Hospi

2023(See, e.g., In re A.M., supra, 224 Cal.App.4th at pp. 599–600.) B.