The question of whether a party had "notice and an opportunity to be heard" within the meaning of RSA 458–A:16, II should be interpreted as requiring that the party had "a full and fair opportunity to be heard before an impartial tribunal that conducted the proceedings in a regular fashion." Id. at 1015–16 (quotation omitted); accord Poluhovich v. Pellerano, 373 N.J.Super. 319, 861 A.2d 205, 242 (App.Div.2004) (stating that "a finding that those procedures and criteria [of the courts of the Dominican Republic] are the substantial equivalent of those in New Jersey is not the test to be applied when determining whether the jurisdictional criteria set forth in the UCCJA or UCCJEA should be given application"). Several courts have addressed this issue under the UCCJEA.

Greely v. Greely, 194 N.J. 168, 178, 943 A.2d 841 (2008). See also Poluhovich v. Pellerano, 373 N.J.Super. 319, 352, 861 A.2d 205 (App.Div.2004) (addressing subject matter jurisdiction under the Uniform Child Custody Jurisdiction Act (UCCJA), N.J.S.A. 2A:34–28 to –52, the predecessor of the UCCJEA), certif. denied,183 N.J. 212, 871 A.2d 90 (2005).

, it is well settled that such an analysis would have been inappropriate in connection with a UCCJEA jurisdictional determination. See Poluhovich v. Pellerano, 373 N.J.Super. 319, 366 (App. Div. 2004) (noting that "the UCCJEA was not intended to invite an analysis of the merits of a custody dispute when determining jurisdiction"), certif. denied, 183 N.J. 212 (2005). In that vein, although respondent maintained that the UCCJEA was "a bad law" because it allowed his daughter "to be raised 800 miles away from both parents[,]" respondent failed to recognize the UCCJEA was enacted to resolve jurisdictional conflicts rather than to resolve the merits of an underlying custody dispute.

March 1, 2005 Appeal from 373 N.J.Super. 319, 861 A.2d 205. Petition for certification denied.

Accordingly, to address a multi-state child custody issue, a Family Part must follow the procedures set forth in the UCCJEA. Id. at 171 (citing Poluhovich v. Pellerano, 373 N.J.Super. 319, 357 (App. Div. 2004)).

To address a multi-state child custody issue, courts in the Family Part are to follow the procedures in the UCCJEA. Sajjad, 428 N.J.Super. at 171 (citing Poluhovich v. Pellerano, 373 N.J.Super. 319, 357 (App. Div. 2004)).

To address a multi-state child custody issue, courts in the Family Part are to follow the procedures in the UCCJEA. Id. at 171 (citing Poluhovich v. Pellerano, 373 N.J.Super. 319, 357 (App. Div. 2004)).

Ibid. (citing Poluhovich v. Pellerano, 373 N.J.Super. 319, 357 (App. Div. 2004)).

To address a multi-state child custody issue, courts in the Family Part are to follow the procedures in the UCCJEA. Ibid. (citing Poluhovich v. Pellarano, 373 N.J. Super. 319, 357 (App. Div. 2004)). A state that has made the initial custody determination has exclusive, continuing jurisdiction over later disputes.

"We will consider the official comments to a model statute in construing our own version of the model act, and, likewise, will consider later amendments insofar as 'the legislative policy and intent of the new statute may inform interpretation and application of the existing version of the statute.'" Marshak, 390 N.J. Super. at 392 (internal citation omitted) (quoting Poluhovich v. Pellerano, 373 N.J. Super. 319, 354 (App. Div. 2004)). In this case, Robert turned eighteen and graduated high school before the September 2016 motions were filed.