Byard v. Byler

The issue presented by this case is whether Ohio’s Uniform Reciprocal Enforcement of Support Act (“URESA”), R.C. Chapter 3115, grants a court subject matter jurisdiction to determine child custody and visitation rights. The purpose of URESA is to “improve and extend by reciprocal legislation the enforcement of duties of support ” across state lines. (Emphasis added.) R.C. 3115.01(A); Levi v. Levi (1960), 170 Ohio St. 533, 11 O.O.2d 364, 166 N.E.2d 744, syllabus. More specifically, R.C. 3115.29 strictly limits to matters of support the court’s subject matter jurisdiction in a URESA action:

“Part…