Family Court Advisory and Rules Committee

Child Support and Paternity Legislative Agenda

Selected Bills

January, 2006

1. Duration of term of probation and procedures

for violations of probation in child support proceedings

(FCA §§454, 456)

In order to realize the statutory goal of providing adequate support to New York’s children, the Family Court must be able to rigorously enforce its orders. To do that, it must be able to secure compliance through imposition of a diverse array of sanctions that are appropriate in severity and responsive to the individual problems presented. License suspensions, Department of Taxation and Finance referrals, lottery and tax refund interceptions, sequestration of property, imposition of income deduction orders and referrals to rehabilitative or work programs, where available, all may be helpful in particular cases. See Family Court Act §454, et seq. However, in particularly intractable cases, including those involving child support obligors who are self-employed or who are paid in cash or “off the books,” the ultimate sanction of incarceration may be the only meaningful sanction currently available to the Court. Clearly, incarceration, which at least temporarily cuts off a support obligor’s earning capacity altogether, is a costly, sometimes self-defeating option that must be reserved for cases in which lesser sanctions have been exhausted or are not efficacious.

Along the continuum of child support sanctions, there must be a means of providing regular, in-person monitoring by someone in authority who can compel a change of behavior under threat of a more serious sanction and who may be able, at the same time, to provide services and rehabilitative assistance to the support obligor that will facilitate compliance with child support obligations. That vital in-person monitoring and provision of individualized assistance may best be provided by placing a support obligor on probation. However, while explicitly authorized in the Family Court Act, probation has proven to be an unworkable and rarely-utilized tool in Family Court child support cases. The Family Court Advisory and Rules Committee has identified statutory impediments to the effective use of probation in child support cases and is proposing a measure to address these problems.

First, in order to make probation less costly for local probation departments and fairer to the probationers, the proposal would impose a limit on the duration of probation more commensurate with probation in other contexts. Alone among probation provisions in both the Family Court Act and Criminal Procedure Law, Family Court Act §456 permits a child support obligor to be placed on probation for an extended period of time, that is, the entire duration of a child support or visitation order or order of protection. Since a child support order may last until the youngest child reaches the age of 21, this may mean more than two decades of probation – four times greater than the duration of probation for all but the most serious felonies. Cf. Penal Law §65(3). This disproportionate degree of supervision is beyond the capacity of most local probation departments to provide, particularly in times of fiscal constraint, and may explain the reluctance of probation departments to become involved in child support matters. The Committee’s proposal, therefore, would impose the same time limit that exists for person in need of supervision (PINS) cases in Family Court – that is, not more than one year, a period that may be extended, after notice to the support obligor and an opportunity to be heard, for an additional year upon a finding of exceptional circumstances.

Second, Family Court Act §456 is entirely silent regarding procedures to be followed in the event of a violation of probation. All too often, the burden falls upon custodial parents to take time off from work to prepare, file and arrange service of violation petitions. Again comparable to other probation violation provisions, the Committee’s proposal would instead require the local probation department to file a verified probation violation petition and would provide an opportunity for the probationer and parties to be to be heard as prerequisites to revocation of probation in the event of a willful violation. The measure would further provide that the period of probation would be tolled as of the date of filing of the violation petition and that in the event the violation petition is not sustained, the tolling period would be credited to the period of probation. Providing a mechanism consistent with due process to bring alleged child support violators to the attention of the Family Court would benefit the families as well – taking the onus off of custodial parents to initiate and prosecute violation proceedings that should instead be handled by local probation departments.

Enactment of this measure would make probation a viable alternative for probation departments, would improve the collection of child support for the children in the State, would make the probation provisions fairer for support obligors and would greatly enhance the Family Court’s capacity to respond effectively to the wide variety of child support cases before it.

Proposal

AN ACT to amend the family court act, in relation to probation in child support cases

The People of the State of New York, represented in Senate and Assembly, do enact as follows:

Section 1. Paragraph (c) of subdivision 3 of section 454 of the family court act is amended to read as follows:

(c) place the party on probation [under] for up to one year pursuant to section four hundred fifty-six of this article upon such conditions as the court may determine and in accordance with the provisions of the criminal procedure law; or.

§2. Section 456 of the family court act, as added by chapter 809 of the laws of 1963, is amended to read as follows:

§456. Probation. (a) No person may be placed on probation under this article unless the court makes an order to that effect, either at the time of the making of an order of support or under section four hundred fifty-four. The order of probation may contain such conditions as the court may determine. The maximum period of probation may [continue so long as an order of support, order of protection or order of visitation applies to such person] not exceed one year. If the court finds, at the conclusion of the original period, upon notice and an opportunity to be heard, that exceptional circumstances require an additional year of probation, the court may continue probation for an additional year.

(b) [The] If the court [may at any time, where circumstances warrant it, revoke an order of] finds, after a hearing, that a party who has been placed on probation [. Upon such revocation, the probationer shall be brought to court, which may, without further hearing,] in accordance with this section, has willfully violated any term or condition of probation, the court, after giving notice and an opportunity to be heard to the parties and law guardian, if any, may revoke such order of probation and may make any order [that might have been made at the time the order of probation was made] authorized by section four hundred fifty-four of this article. No such finding may be made unless a verified petition containing specific allegations constituting the violation is filed with the court and duly served upon the parties. The period of probation shall be deemed tolled as of the date of filing of the probation violation petition, but, in the event that the court does not find that the order of probation was willfully violated, the period of such interruption shall be credited to the period of probation.

§3. This act shall take effect immediately.

2. Modification of orders of child support in family court and matrimonial proceedings

(FCA §§451, 461; DRL §236B(9)(b))

Examination of the New York State statutory framework for child support reveals layers of enactments, a patchwork of provisions that do not cohere into an integrated, internally-consistent whole. The standards applicable to modifications of child support orders are examples of contradictory statutory layers that lead to disparate and sometimes unfair results for both parents and, importantly, their children. The Family Court Advisory and Rules Committee is proposing a measure to lessen the disparity and make more uniform the provisions regarding modification in the Family Court Act and Domestic Relations Law.

The Child Support Standards Act (CSSA), enacted in 1989, was designed to ensure that the children of New York are adequately supported and share fairly in the earnings and resources of their parents. The CSSA contains a formula-driven mechanism to accomplishes this purpose, at least at the time of the initial child support determination. In the early 1990's, pursuant to federal mandate, a “review and adjustment” procedure was added that required periodic adjustment of child support orders in cases involving families on public assistance or upon the request of custodial parents who had applied for child support collection and enforcement and/or paternity establishment services pursuant to section 111-g of the Social Services Law. Before the “review and adjustment” provisions were fully implemented, the federal Personal Responsibility and Work Opportunity Reconciliation Act of 1996 was enacted, which, inter alia, gave States the option of replacing the “review and adjustment” provisions with an automatic “cost of living adjustment” (“COLA”). See 42 U.S.C. §666(a)(10)(A) [Public Law 104-193] . With the passage of its welfare reform legislation in 1997, New York State availed itself of this option, again making it applicable to custodial parents on public assistance and others who have requested child support and/or paternity services. See Social Services Law §111-n [Laws of 1997, ch. 398]. Orders issued prior to 1989 were made subject to a one-time “review and adjustment,” after which all child support orders in public assistance and, upon request, in child support and paternity services cases were made subject to the “cost of living adjustment” every two years. The statute contained a procedure for challenging a COLA, which, when invoked by either party, would result in either issuance of a whole new order of support under the CSSA standards or an order declining the adjustment. See Family Court Act §413-a(3)(b); Domestic Relations Law §240-c(3)(b); Social Services Law §111-n(5).

These “review and adjustment” and “COLA” provisions, enacted to comply with the requirements of Title IV-D of the federal Social Security Act [42 U.S.C..] for New York State’s receipt of federal IV-D funding, were super-imposed upon a long-standing methodology for the modification of child support obligations, articulated in the Family Court Act and Domestic Relations Law and shaped by case law. A litigant not covered by these provisions is required to demonstrate an “unforeseen change in circumstances” as a prerequisite to a modification of a child support order – in essence, as a prerequisite to gaining access to the CSSA provisions if the original order had not been issued within those standards. See Matter of Boden v. Boden, 42 N.Y.2d 210, 213 (1977). In Matter of Brescia v. Fitts, 56 N.Y.2d 132, 139-40 (1982), the Court of Appeals further permitted modification based upon the child’s right to adequate support. The recent COLA provisions contain the caveat that “[n]othing herein shall be deemed in any way to limit, restrict, expand or impair the rights of any party to file for a modification of a child support order as is otherwise provided by law.” Family Court Act §413-a(4); Domestic Relations Law §240-c(4).

However, in reality, the provisions do just that – that is, litigants in public assistance and child support and paternity enforcement services cases may obtain a full review and a new Child Support Standards Act order without the showing of a change in circumstances required for all other litigants. As the Court of Appeals held, in Tompkins County Support Collection Unit on behalf of Linda S. Chamberlin v. Boyd M. Chamberlin, 99 N.Y.2d 328 (2003), a challenge to a COLA brings up the whole child support order for review, not simply the COLA itself: “Family Court did not err in entering an order in accordance with the CSSA guidelines rather than merely determining whether or not the COLA amount should be applied.” Id. at 337.

The Committee proposes to remedy this disparity by giving all litigants in child support matters the opportunity for periodic review of child support orders without requiring a showing of a change in circumstances. While the provisions authorizing modifications at any time that the requisite showing can be made would continue, all litigants would also have standing to apply for a modification every three years without making the showing required by the Boden and Brescia cases. Recognizing the need to honor the sanctity of agreements, however, the measure would exempt cases in which the parties have specifically opted out of the three-year modification provision in a written agreement or stipulation to a court order of child support.

This proposal would thus resolve the disparity between public and private child support cases in a clear and fair fashion. It would continue to allow either party to seek a modification at any time during the duration of the child support order, should a traditional change of circumstances occur. It would continue the COLA provisions for public assistance and child support enforcement cases, but would also allow children and their families in other cases to access the benefits of the Child Support Standards Act at least every three years. This change would further the goals of broadening the reach of the CSSA to provide adequate support for more children and would, at the same time, be entirely consistent with the federal child support mandates applicable to New York State.

Proposal

AN ACT to amend the family court act and the domestic relations law, in relation to modification of child support orders

The People of the State of New York, represented in Senate and Assembly, do enact as follows:

Section 1. Section 451 of the family court act, as amended by chapter 533 of the laws of 1999, is amended by adding a new last paragraph to read as follows:

§451. Continuing jurisdiction.

Except as provided in article five-B of this act, the court has continuing jurisdiction over any support proceeding brought under this article until its judgment is completely satisfied and may modify, set aside or vacate any order issued in the course of the proceeding, provided, however, that the modification, set aside or vacatur shall not reduce or annul child support arrears accrued prior to the making of an application pursuant to this section. The court shall not reduce or annul any other arrears unless the defaulting party shows good cause for failure to make application for relief from the judgment or order directing payment prior to the accrual of the arrears, in which case the facts and circumstances constituting such good cause shall be set forth in a written memorandum of decision. A modification may increase support payments [nunc pro tunc as of] retroactively to the date of the initial application for support based on newly discovered evidence. Any retroactive amount of support due shall be paid in one lump sum or periodic sums, as the court directs, taking into account any amount of support which has been paid. Upon an application to modify, set aside or vacate an order of support, no hearing shall be required unless such application shall be supported by affidavit and other evidentiary material sufficient to establish a prima facie case for the relief requested.

An application to modify an order of support and to establish a new order of support in accordance with the child support standards as set forth in section four hundred thirteen of this article may be made on the grounds of (i) newly discovered evidence, (ii) a change in circumstances as defined in paragraph b of subdivision nine of part B of section two hundred thirty-six of the domestic relations law, or (iii) the fact that more than three years have elapsed since the issuance of the order. Nothing contained in this section shall prevent the parties from entering into a written agreement or stipulation to a court order for child support that precludes any subsequent modification in the absence of newly discovered evidence or a change in circumstances and/or that provides that the supreme court shall retain exclusive jurisdiction to modify, set aside, vacate or enforce the order.

§2. Paragraph (ii) of subdivision (b) of section 461 of the family court act, as amended by chapter 28 of the laws of 1970, is amended to read as follows:

(ii) entertain an application to modify such order on the ground that changed circumstances or newly discovered evidence requires such modification or upon the ground that more than three years have elapsed since the date of the order in accordance with section four hundred fifty-one of this article, unless the order of the supreme court provides that the supreme court retains exclusive jurisdiction to enforce or modify the order.

§3. Paragraph b of subdivision 9 of part B of section 236 of the domestic relations law, as amended by chapter 354 of the laws of 1993, is amended to read as follows:

b. Upon application by either party, the court may annul or modify any prior order or judgment as to maintenance or child support, upon a showing of the recipient's inability to be self-supporting or a substantial change in circumstance or termination of child support awarded pursuant to section two hundred forty of this article, including financial hardship. Where, after the effective date of this part, a separation agreement remains in force no modification of a prior order or judgment incorporating the terms of said agreement shall be made as to maintenance without a showing of extreme hardship on either party in which event the judgment or order as modified shall supersede the terms of the prior agreement and judgment for such period of time and under such circumstances as the court determines. [Provided] The court may, however, [that no] annul or modify a prior order or judgment of child support in the absence of such a showing in any case in which more than three years have elapsed since the issuance of the order, Nothing contained in this section shall prevent the parties from entering into a written agreement or stipulation to a court order for child support that precludes any subsequent modification in the absence of a substantial change in circumstances. No modification or annulment shall reduce or annul any arrears of child support which have accrued prior to the date of application to annul or modify any prior order or judgment as to child support. The court shall not reduce or annul any arrears of maintenance which have been reduced to final judgment pursuant to section two hundred forty-four of this chapter. No other arrears of maintenance which have accrued prior to the making of such application shall be subject to modification or annulment unless the defaulting party shows good cause for failure to make application for relief from the judgment or order directing such payment prior to the accrual of such arrears and the facts and circumstances constituting good cause are set forth in a written memorandum of decision. [Such] A modification may increase maintenance or child support [nunc pro tunc as of] retroactively to the date of application based on newly discovered evidence. Any retroactive amount of maintenance, or child support due shall, except as provided for herein, be paid in one sum or periodic sums, as the court directs, taking into account any temporary or partial payments which have been made. Any retroactive amount of child support due shall be support arrears/past due support. In addition, such retroactive child support shall be enforceable in any manner provided by law including, but not limited to, an execution for support enforcement pursuant to subdivision (b) of section fifty-two hundred forty-one of the civil practice law and rules. When a child receiving support is a public assistance recipient, or the order of support is being enforced or is to be enforced pursuant to section one hundred eleven-g of the social services law, the court shall establish the amount of retroactive child support and notify the parties that such amount shall be enforced by the support collection unit pursuant to an execution for support enforcement as provided for in subdivision (b) of section fifty-two hundred forty-one of the civil practice law and rules, or in such periodic payments as would have been authorized had such an execution been issued. In such case, the court shall not direct the schedule of repayment of retroactive support. The provisions of this subdivision shall not apply to a separation agreement made prior to the effective date of this part.

§4. This action shall take effect on the ninetieth day after it shall have become law.

While explicitly not diminishing the non-custodial parent’s basic support obligation and in no way superseding the issuance of orders for periodic payments pursuant to the Child Support Standards Act, the proposal would authorize the Supreme or Family Court, under such terms and conditions as it deems appropriate, to direct the non-custodial parent to pay an amount to establish a security account designated for the benefit of the child, including, but not limited to, a trust account or annuity, to meet the child’s future needs. The proposal would require the Court to be specific in setting forth the parameters of the account, including, as applicable, the specific purposes of the account; the person or entity that will act as trustee, custodian or administrator of the funds in the account; the person or entity that will act as the trustee, custodian or administrator of the funds in the account in the event of the death of the designated trustee, custodian or administrator; the disposition of the funds after the emancipation or death of the child or children named as beneficiaries; the particular structure that will fulfill the purposes of the account; and any further provisions necessary to accomplish the purpose of the account.

Proposal:

AN ACT to amend the domestic relations law and the family court act, in relation to the authority of the court to direct establishment of a trust or other designated account for the benefit of children in matrimonial, child support and paternity cases

The People of the State of New York, represented in Senate and Assembly, do

enact as follows:

Section 1. Paragraph (c) of subdivision 1-b of section 240 of the domestic relations law is amended by adding a new subparagraph 8 to read as follows:

(8). In addition to the basic child support obligation ordered under this subdivision, the court may, in its discretion, order the respondent to pay an amount to establish a security account designated for the benefit of the child, including, but not limited to, a trust account or annuity to meet the child’s future needs. The court may direct the establishment of such an account under such terms and conditions as it deems appropriate. The court shall set forth, as applicable: the specific purposes of the account; the person or entity that will act as trustee, custodian or administrator of the funds in the account; the person or entity that will act as the trustee, custodian or administrator of the funds in the account in the event of the death of the designated trustee, custodian or administrator; the disposition of the funds after the emancipation or death of the child or children named as beneficiaries; the particular structure that will fulfill the purposes of the account; and any further provisions necessary to accomplish the purpose of the account. The establishment of such an account shall not diminish any current child support obligations.

§2. Paragraph (c) of subdivision 1 of section 413 of the family court act is amended by adding a new subparagraph 8 to read as follows:

4. Second Families

(This proposal is in draft form and has not yet been finalized)

The Courts daily must address, with little statutory guidance, the problem of quantifying the treatment ‘second families’ in child support determinations. Currently, in order to give consideration for support to children who are not subject, for various reasons, to Court order the Court must find a variance pursuant to §413-(f)(8) of the Family Court Act and §240(f)(8) of the Domestic Relations Law. This is a difficult burden to meet for seasoned practitioners, a near impossible one for pro se litigants. One suggestion is to treat non-ordered child support for a second family as if that support was actually ordered and paid.

This legislative change could be accomplished by focusing on §413-1 (b)(5)(vii) of the Family Court Act---§240(b)(5)(vii) of the Domestic Relations Law, i.e., amounts deducted from income prior to applying the percentages. There could be inserted a new subparagraph entitled subparagraph (E); present subparagraphs E, F, G and H could be renumbered. The new subparagraph (E) would read something like the following:

“(E) Child support that would be paid for any child or children living and residing the parent and not subject to the instant action, for whom the parent has the legal duty of support, and as if the provisions of this Section were applied. This deduction shall be considered presumptive and said presumption may be rebutted by the appropriate proof.”

Subparagraph 413-1(f)(8) of the Family Court Act—subparagraph 240(f)(8)---could then be deleted.

This would not be a perfect fix. Practitioners understand that the dollar for dollar credit given for child support being paid by order for other children is often not significant. However, this would provide a workable approach to the problem, and one that could be rebutted to achieve a more beneficial result if the proof is appropriate.

5. Family Court Act Section 413-1(h).

(This proposal is in draft form and has not yet been finalized)

Section 413-1(h) of the Family Court Act and section (h) of the Domestic Relations Law provide protections to custodial parents and non-custodial parents upon entering an agreement to pay and receive child support. The statutes provide that a validly executed agreement or stipulation entered into by the parties and presented to the Court for incorporation into an order or judgment shall include:

- a provision stating that the parties were advised of the provisions of the Child Support Standards Act

-a provision stating that the basic amount is the presumptively correct amount of child support.

–and if the agreement deviates from the guidelines, the agreement must specify the amount of the basic child support and the reasons for deviating (generally known as ‘opting out rules’).

This provision may not be waived by either party or attorney.

Many issues continue to plague the Courts when one or more of the provisions of the statute are out of compliance. Some examples (in no particular order):

☞ What is the remedy for a bad agreement and/or order?

☞ Is the agreement/order void and unenforceable and must a new obligation then be established to the initial date of filing?

☞ If so, is this new obligation then based on the parties’ circumstances when the issue presently arises or at the time the agreement was entered?

☞ What about changes that may have taken place if a number of years have gone by?

☞ Or is the remedy to treat the obligation as enforceable to the date the issue is raised and then to establish a new obligation de novo from that point? (Note that this may not be the most logical resolution---if the agreement/order is void, it’s just that, isn’t it?).

☞ It is somewhat obvious that this section was enacted to protect custodial parents. Should this be made clear, i.e., that the non-custodial parent cannot raise the issue as a defense?

☞ Can and should the Court raise this issue sua sponte?

☞ And if a party raises the issue, must it be done as an affirmative defense, on papers?

☞ Can a Support Magistrate declare a Supreme Court agreement/order non-enforceable?

☞ What if this rises in the context of a violation proceeding? Is this a defense?

☞Etc.

The courts have consistently held that the failure to comply with these opting out rules will result in an invalid or unenforceable child support order. However, there has not been clear guidance about the effect of the vacature of a child support award or the next procedural step the parties must take, and how to deal with the issues raised above. The most recent case of note to address this was Jefferson v. Jefferson, 2005 WL 2154697 (2^nd Dept., 2005). The parties entered a written separation agreement in 2000. The agreement provided that the husband would pay child support, but did not take into account the combined parental income in excess of $80,000. The agreement was incorporated but not merged with the judgment of divorce in 2001. In 2004, the ex-wife moved to vacate the child support provisions of the agreement for failure to comply with the CSSA opting out requirements. The court denied her motion and the ex-wife appealed. The Appellate Division reversed. The agreement failed to comply with the CSSA requirements because it did not set forth the presumptively correct amount of support that would have been fixed pursuant to the CSSA, and failed to articulate the reasons for the deviation. The child support provisions of the agreement were invalid and unenforceable. The court should have granted the motion to vacate. The AD remitted for a new determination of child support. The child support order would be based on the parties’ income, expenses, and standard of living in December 2000, when the support agreement was originally executed. Also, see Cardinal v. Cardinal, 713 N.Y.S.2d 370 (2\sect plain ^nd Dept., 2000). Here, the Second Department gives a clear procedure to follow. If the agreement is invalid, the court must go back to the beginning, and set child support as if there had been no agreement. Compare this with the 3^rd Department, where the motion to vacate is essentially treated as a prospective modification. See Clark v. Liska, 692 N.Y.S.2d 825 (3^rd dept 1999). The Liska approach is probably what you see most often in the Courts. It is a daunting task to go back to the time the obligation originated. It may be a number of years, it may have been a part of an involved matrimonial settlement, etc. And, thus far the 4^th Dept hasn’t given specific guidance. So treating it as a request for modification is sometimes the course of least resistance. It can be argued, though, that the Cardinal approach, while a bit of work, logically (and legally) makes sense. Vacating an order does not dismiss the underlying petition, motion, or complaint. It does not eliminate a parent’s duty to support his or her child. The obligation to support is effective retroactively to the earlier of the date when the children became eligible for public assistance or when the custodial parent makes a request for support (by petition in Family Court or by motion or complaint in Supreme), whichever is earlier. An error by the parties and the court in making a valid agreement or stipulation does not change the underlying duty to support. So under Cardinal the court must hold a hearing to determine child support as it would have been awarded at the time the vacated Agreement was entered. The court would then determine the amount due from the effective date to the present, deduct the amount paid by the non-custodial parent under the vacated order, and determine the amount of retroactive support due.

(Note: Thanks to Brian Wootan, Associate Counsel, NYS OTDA, for his help in this analysis.

We must think about a legislative fix. Here’s one suggestion (very rough!):

“(1)A validly executed agreement or stipulation voluntarily entered into between the parties after the effective date of this subdivision presented to the court for incorporation in an order or judgment shall include the following:

(a) a provision stating that the parties have been advised of the provisions of this subdivision and

(b) a provision stating that the basic child support obligation provided for therein would presumptively result in the correct amount of child support to be awarded.

(2) In the event that such agreement or stipulation deviates from the basic child support obligation, the agreement or stipulation must specify the amount that such basic child support obligation would have been and the reason or reasons that such agreement or stipulation does not provide for payment of that amount.

(3) Such provision may not be waived by either party or counsel.

(4) Nothing contained in this subdivision shall be construed to alter the rights of the parties to voluntarily enter into validly executed agreements or stipulations which deviate from the basic child support obligation provided such agreements or stipulations comply with the provisions of this paragraph. The court shall, however, retain discretion with respect to child support pursuant to this section.

(5) Any court order or judgment incorporating a validly executed agreement or stipulation which deviates from the basic child support obligation shall set forth the court's reasons for such deviation.

(6) An agreement, stipulation or Court order which fails to comply with any of the provisions of this subsection shall be deemed void as of the date either of the parties raises said failure to comply in writing; or a Court of competent jurisdiction makes a finding of said failure to comply in writing.

(7) If a Court of competent jurisdiction finds that an agreement, stipulation or Court order fails to comply with any of the provisions of this subsection, the court shall hold a hearing and determine the child support obligations of the parties pursuant to this section de novo from the time said issue was raised in writing by either of the parties or the Court.

(8) The provisions of this subsection shall not constitute a defense to non-payment of a child support obligation prior to the issues in this subsection being raised by the parties or the Court in writing in a Court of competent jurisdiction.”

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