Numerous state courts have concluded that, where there is a conflict between the PKPA and the UCCJA, the language of the PKPA indicates Congress intended to preempt custody jurisdiction and those courts have accorded preference to the PKPA and the home state rule under the supremacy clause of our federal constitution (U.S. Const., Art. VI). See, e.g., cases cited in Doucette v. Murray, 1997 WL 381389 (Conn.Super. July 1, 1997). Both the PKPA and the UCCJA define "home state" as the state in which a child has lived with a parent or person acting as a parent "for at least six consecutive months" immediately preceding initiation of the custody matter.
The Defendant's attempts to rely on the Connecticut Uniform Child Custody Jurisdiction Act and the federal Parental Kidnapping Prevention Act are misplaced and inappropriate under the law. See Perez v. Perez, 212 Conn. 63 (1989) Ozkan v. Ozkan, 18 Conn. App. 73 (1985) Brown v. Brown, 195 Conn. 98 (1985) and Agnello v. Becker, 184 Conn. 421 (1981) See also In Re Anthony R., 41 Conn. Sup. 505 (1990) See also the following Connecticut Trial Court Unpublished Decisions: Seldon v. Dunn No. 112255 (April 14, 1998) Doucette v. Murray No. 0541490 (Jul 1, 1997) and Andrews v. Andrews No. FA92 300136 (Jan 8, 1993). In his own Affidavits, the Defendant states that the Plaintiff moved to Idaho in 1988.