Vannatta v. Boulds

¶1 Barrie L. Boulds (Boulds) appeals the District Court’s order amending a custody decree and naming Trevor Vannatta (Vannatta) as their minor child’s primary residential caregiver. We reverse.

¶2 The issue on appeal is whether, under the Uniform Child Custody Jurisdiction and Enforcement Act and the Parental Kidnapping and Prevention Act, the Montana District Court lacked subject matter jurisdiction to modify the original custody decree from the State of North Dakota?

Factual and Procedural Background

¶3 Boulds and Vannatta were married in May of 1997. Their one child (Sydney) was born in…