However, our lower courts have generally approached the limitations imposed by the UCCJA as equivalent to declarations of subject matter jurisdiction which mandate that the jurisdictional requirements of the UCCJA be met when the custody request is filed. See Miller v. Harper, 99-316 (La.App. 3 Cir. 10/13/99), 747 So.2d 642, 644; Renno v. Evans, 580 So.2d 945, 948 (La.App. 2 Cir. 1991). The UCCJA provides four alternatives as a basis for a state to assert jurisdiction: (1) "home state" jurisdiction; (2) "significant connection" jurisdiction; (3) "emergency" jurisdiction; and (4) "residual" jurisdiction.
Where the lack of subject matter jurisdiction is not apparent on the face of the plaintiff's petition, the burden is on the defendant to offer evidence in support of the exception. La. C.C.P. art. 930; Miller v. Harper, 99–316 (La.App.3d Cir.10/13/99), 747 So.2d 642;Crockett v. State, Through Dept. of Public Safety and Corrections, 97–2528 (La.App.1st Cir.11/6/98), 721 So.2d 1081,writ denied,98–2997 (La.1/29/99), 736 So.2d 838. Here, the burden is on Shady Lake to prove that it is entitled to tort immunity under the workers' compensation provisions.