Pahnke/Office of Child Support v. Pahnke

Summary

The court held that the father waived any objection to defective service by participating in the modification proceedings without timely asserting the defense. It also upheld Vermont's personal jurisdiction and subject-matter jurisdiction under UIFSA because the father's contacts with Vermont satisfied due process and all parties resided in Vermont when the modification motion was filed. The court affirmed the prospective modification effective from the filing date but remanded for recalculation because accrued support under the Michigan order could not be retroactively eliminated. No separate opinions were filed.