State of Tennesse ex rel. Spurlock v. Torres (Tennessee 2017)

A child support order is void if the court did not have personal jurisdiction over the respondent parent. In interstate actions, there are specific requirements for personal jurisdiction over a nonresident parent, one of which is the parent has entered an appearance or filed a responsive document. In this contempt proceeding, the father, a Texas resident, filed a motion to dismiss for lack of personal jurisdiction. The trial court found it had personal jurisdiction under two grounds: he had requested an administrative review of the arrears that could be considered a responsive pleading and he had sufficient contact with the state of Tennessee to satisfy the catchall provision. The appellate court disagreed. A request for administrative review is not a document intended for filing with the court and did not satisfy the jurisdictional requirement. The court also found the catchall was not appropriate. The father had made one trip to Tennessee and paid minimal child support. These activities were not enough to pass the minimum contacts test.