Virginia Restraining Order Emergency Temporary Protective Order Domestic Violence New Kent County Juvenile Domestic Relations District Court Custody

BONNY FOSTER v. DANIEL SEAN FOSTERstated that it considered the statutory factors, and
COURT OF APPEALS OF VIRGINIAspecifically noted that it considered mother's
52 Va. App. 523assertions of domestic violence in determining that
August 12, 2008, DecidedVirginia was not an "inconvenient forum." On the
On September 5, 2006, father filed petitions in therecord presented on appeal, we conclude that the
New Kent County Juvenile and Domestic Relationscircuit court did not abuse its discretion in finding that
District Court (JDR court) seeking custody of theVirginia was not an "inconvenient forum." Moreover,
three children. Two days later, on September 7,the Maine court, which had earlier entered the
2006, mother, unaware of father's petition foremergency restraining order based on mother's
custody of the children in Virginia, obtained an exassertion of domestic violence, concurred with the
parte  temporary protective order from the Cariboucircuit court's determination that Virginia was not an
District Court in Maine (Maine court), alleging domestic"inconvenient forum" to determine the custody
violence on the part of father toward her and theand visitation of the parties' children, and declined to
three children. In the same ex parte proceeding, thecontinue to exercise its jurisdiction under its
Maine court awarded mother temporary custody of"emergency order."
the children.This Court finds that the trial court did not abuse its
Whether the circuit court erred in finding that thediscretion in holding that the Virginia was not an
Virginia was the appropriate jurisdiction for custody ininconvenient forum.
light of the facts before the court regardingDisclaimer:
domestic violence?These summaries are provided by the SRIS Law
The Court held that the parties' evidence concerningGroup.  They represent the firm's unofficial views of
each of the eight factors, including mother's evidencethe Justices' opinions.  The original opinions should be
of domestic violence. The circuit court expresslyconsulted for their authoritative content.