Oregon Revised Statutes

Or. Rev. Stat. § 109.761 (2026)

Inconvenient forum

✓ current as of May 2026
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      109.761 Inconvenient forum. (1) A court of this state that has jurisdiction under ORS 109.701 to 109.834 to make a child custody determination may decline to exercise its jurisdiction at any time if the court determines that it is an inconvenient forum under the circumstances and that a court of another state is a more appropriate forum. The issue of inconvenient forum may be raised upon the motion of a party, the court’s own motion or the request of another court.

      (2) Before determining whether a court of this state is an inconvenient forum, the court shall consider whether it is appropriate for a court of another state to exercise jurisdiction. For this purpose, the court shall allow the parties to submit information and shall consider all relevant factors, including:

      (a) Whether domestic violence has occurred and is likely to continue in the future and which state could best protect the parties and the child;

      (b) The length of time the child has resided outside this state;

      (c) The distance between the court in this state and the court in the state that would assume jurisdiction;

      (d) The relative financial circumstances of the parties;

      (e) Any agreement of the parties as to which state should assume jurisdiction;

      (f) The nature and location of the evidence required to resolve the pending litigation, including testimony of the child;

      (g) The ability of the court of each state to decide the issue expeditiously and the procedures necessary to present the evidence; and

      (h) The familiarity of the court of each state with the facts and issues in the pending litigation.

      (3) If a court of this state determines that it is an inconvenient forum and that a court of another state is a more appropriate forum, it shall stay the proceedings upon condition that a child custody proceeding be promptly commenced in another designated state and may impose any other condition the court considers just and proper.

      (4) A court of this state may decline to exercise its jurisdiction under ORS 109.701 to 109.834 if a child custody determination is incidental to an action for divorce or another proceeding while still retaining jurisdiction over the divorce or other proceeding. [1999 c.649 §19]

 

      Note: See note under 109.701.

Notes of Decisions
Cited in 18 cases (6 in the last 5 years), 2002–2026 · leading case: Matter of Marriage of Medill, 40 P.3d 1087 (Or. Ct. App. 2002).
Matter of Marriage of Medill, 40 P.3d 1087 (Or. Ct. App. 2002). · cites it 26× “the proceeding and the child is absent from this state but a parent or *1095 person acting as a parent continues to live in this state; "(b) A court of another state does not have jurisdiction under subsection (1)(a) of this section, or a court of the home state of the child has…”
Campbell v. Tardio, 323 P.3d 317 (Or. Ct. App. 2014). · cites it 2× “nt of the proceeding and the child is absent from this state but a parent or person acting as a parent continues to live in this state; “(b) A court of another state does not have jurisdiction under subsection (l)(a) of this section, or a court of the home state of the child has…”
Dep't of Human Servs. v. M. H., 300 P.3d 1262 (Or. Ct. App. 2013). · cites it 2× “the proceeding and the child is absent from this state but a parent or person acting as a parent continues to live in this state; “(b) A court of another state does not have jurisdiction under subsection (l)(a) of this section, or a court of the home state of the child has…”
Mayfield & Mayfield, 474 P.3d 454 (Or. Ct. App. 2020). · cites it 10× “744(1)(a), on the basis that the chil- dren do not have a significant connection with Oregon and that substantial evi- dence is no longer available in Oregon, and second, under ORS 109.761, on the basis that Oregon is an inconvenient forum and that Washington is a more appro-…”
Dept. of Human Servs. v. J. A. G., 344 Or. App. 511 (Or. Ct. App. 2025). · cites it 2× “nt of the proceeding and the child is absent from this state but a parent or person acting as a parent continues to live in this state; “(b) A court of another state does not have jurisdiction under subsection (1)(a) of this section, or a court of the home state of the child has…”
Dept. of Human Servs. v. J. S., 303 Or. App. 324 (Or. Ct. App. 2020). “See ORS 109.761 (pro- viding that, if an Oregon court has initial-custody jurisdic- tion but decides that a court of another state is a more appro- priate forum, the Oregon court “shall stay the proceedings Cite as 303 Or App 324 (2020) 337 upon condition that a child custody…”
Dep't of Human Servs. v. G. G., 229 P.3d 621 (Or. Ct. App. 2010). “One purpose of the UCCJEA is to grant Oregon temporary emergency jurisdiction to protect a child in this state. ORS 109.751. Another purpose of the UCCJEA is to determine whether this state is an inconvenient forum and whether another state is a more appropriate forum.”
Espinoza v. Evergreen Helicopters, Inc., 337 P.3d 169 (Or. Ct. App. 2014). · cites it 2× “110(l)(c), and when, in a child custody case, the court determines “that it is an inconvenient forum under the circumstances and that a court of another state is a more appropriate forum,” ORS 109.761. Because the legislature has not adopted a more broadly applicable…”
Dep't of Human Servs. v. R. M. S., 383 P.3d 417 (Or. Ct. App. 2016). · cites it 2× “the proceeding and the child is absent from this state but a parent or person acting as a parent continues to live in this state; *809 “(b) A court of another state does not have jurisdiction under subsection (l)(a) of this section, or a court of the home state of the child has…”
Snow v. Snow, 74 P.3d 1137 (Or. Ct. App. 2003). “744 or that a court of this state would be amore convenient forum under ORS 109.761; or “(2) A court of this state or a court of the other state determines that the child, the child’s parents and any person acting as a parent do not presently reside in the other state.”
Dep't of Human Servs. v. T.F. (In re M.L.F.), 425 P.3d 480 (Or. Ct. App. 2018). · cites it 2× “nt of the proceeding and the child is absent from this state but a parent or person acting as a parent continues to live in this state; "(b) A court of another state does not have jurisdiction under subsection (1)(a) of this section, or a court of the home state of the child has…”
Dep't of Human Servs. v. S. C. S., 290 P.3d 903 (Or. Ct. App. 2012). · cites it 2× “nt of the proceeding and the child is absent from this state but a parent or person acting as a parent continues to live in this state; “(b) A court of another state does not have jurisdiction under subsection (l)(a) of this section, or a court of the home state of the child has…”
— Or. Rev. Stat. § 109.761(1) — 5 cases
Dep't of Human Servs. v. G. G., 229 P.3d 621 (Or. Ct. App. 2010). “One purpose of the UCCJEA is to grant Oregon temporary emergency jurisdiction to protect a child in this state. ORS 109.751. Another purpose of the UCCJEA is to determine whether this state is an inconvenient forum and whether another state is a more appropriate forum.”
Mayfield & Mayfield, 474 P.3d 454 (Or. Ct. App. 2020). “744(1)(a), on the basis that the chil- dren do not have a significant connection with Oregon and that substantial evi- dence is no longer available in Oregon, and second, under ORS 109.761, on the basis that Oregon is an inconvenient forum and that Washington is a more appro-…”
Puhl & Axel, 345 Or. App. 670 (Or. Ct. App. 2025).
Puhl & Axel, 345 Or. App. 670 (Or. Ct. App. 2025).
Skaug & Skaug, 348 Or. App. 38 (Or. Ct. App. 2026).
— Or. Rev. Stat. § 109.761(2) — 1 case
Mayfield & Mayfield, 474 P.3d 454 (Or. Ct. App. 2020). “744(1)(a), on the basis that the chil- dren do not have a significant connection with Oregon and that substantial evi- dence is no longer available in Oregon, and second, under ORS 109.761, on the basis that Oregon is an inconvenient forum and that Washington is a more appro-…”
— Or. Rev. Stat. § 109.761(2)(b) — 1 case
Matter of Marriage of Medill, 40 P.3d 1087 (Or. Ct. App. 2002). “the proceeding and the child is absent from this state but a parent or *1095 person acting as a parent continues to live in this state; "(b) A court of another state does not have jurisdiction under subsection (1)(a) of this section, or a court of the home state of the child has…”
— Or. Rev. Stat. § 109.761(2)(g) — 1 case
Matter of Marriage of Medill, 40 P.3d 1087 (Or. Ct. App. 2002). “the proceeding and the child is absent from this state but a parent or *1095 person acting as a parent continues to live in this state; "(b) A court of another state does not have jurisdiction under subsection (1)(a) of this section, or a court of the home state of the child has…”
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