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Oct. 30, 2025 Get Citation Alerts Download PDF Add Note

In the Matter of Taylor Coyne and Ashley Blanchfield

Supreme Court of New Hampshire

• Citations: None known
• Docket Number: 2024-0419

• Precedential Status: Non-Precedential

• Opinion

• Authorities (4)

• Cited By (0)

• Summaries (0)

• Similar Cases (13.4K)

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Combined Opinion

THE STATE OF NEW HAMPSHIRE

SUPREME COURT

In Case No. 2024-0419, In the Matter of Taylor Coyne and
Ashley Blanchfield, the court on October 30, 2025, issued the
following order:

The court has reviewed the written arguments and the record submitted
on appeal, and has determined to resolve the case by way of this order. See
Sup. Ct. R. 20(3). The respondent, Ashley Blanchfield (Mother), appeals an
order of the Circuit Court (Pendleton, J.) ruling that it retains exclusive,
continuing jurisdiction over a child custody matter between Mother and the
petitioner, Taylor Coyne (Father). We affirm.

I. Background

The trial court found the following facts, or they are supported by the
record. Mother and Father are unmarried and have two children who were
born in 2020. In December 2021, the parties filed a joint stipulation “regarding
relocation and parenting” with the trial court, in which the parties agreed,
among other things, to allow Mother to relocate to Maine with the children for
work purposes. (Capitalization and bolding omitted.) The stipulation provides:
“Both Parties agree that New Hampshire shall maintain jurisdiction over this
matter during the Mother’s relocation and while she resides in Maine for a
minimum of 6 months to one year.” The trial court approved the stipulation in
December 2021 (hereinafter, the relocation order), and Mother moved to Maine
with the children. In January 2023, the court entered a final uniform support
order and a final parenting plan.

In August 2023, Mother filed an affidavit and request to register a foreign
child custody order (the Maine petition) with the Maine District Court pursuant
to Maine’s Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA).
Mother represented that the Maine court had jurisdiction to modify the foreign
child custody order because “[t]he court of the other state has determined that
it no longer has exclusive, continuing jurisdiction . . . or that a Maine court
would be a more convenient forum.” Mother moved to hold Father in contempt
under the final parenting plan and to modify the final plan. Father moved to
dismiss the Maine petition, arguing that the court lacked jurisdiction over the
final parenting plan because New Hampshire maintains exclusive, continuing
jurisdiction over this case.
Following a hearing, the Maine court granted the motion to dismiss. The
court stated that Maine law requires that the New Hampshire court must
determine that it no longer has exclusive, continuing jurisdiction or that a
Maine court would be a more appropriate forum and, in this case, “the New
Hampshire court has not made any such determinations.” The Maine court
found that “[t]he fact that the parties agreed in December 2021 that the New
Hampshire court’s jurisdiction would continue for ‘six months to a year’ does
not surpass or override the requirements of the UCCJEA.” Accordingly, the
court dismissed the Maine petition for lack of jurisdiction.

Mother then filed a petition in the New Hampshire trial court asking it to
relinquish jurisdiction over this case to Maine pursuant to RSA chapter 458-A
(2018). Mother asked the court to confirm that the relocation order
relinquished the court’s jurisdiction over this matter at the end of one year or,
alternatively, to conclude that New Hampshire is an inconvenient forum and
that Maine is a more appropriate forum pursuant to RSA 458-A:18. After
briefing and argument on the issue, the trial court concluded that New
Hampshire retains exclusive, continuing jurisdiction over this matter and that
New Hampshire is not an inconvenient forum. Mother unsuccessfully moved
for reconsideration. This appeal followed.

II. Analysis

Mother argues that the trial court: (1) erred in concluding that New
Hampshire continues to maintain exclusive, continuing jurisdiction over this
matter, see RSA 458-A:13; and (2) unsustainably exercised its discretion by
failing to conclude that New Hampshire is an inconvenient forum and that
Maine is a more appropriate forum, see RSA 458-A:18. We address these
arguments in turn.

A. Exclusive, Continuing Jurisdiction

The task of avoiding jurisdictional conflicts begins with an initial
determination as to which state maintains exclusive, continuing jurisdiction
over child custody determinations. In the Matter of McAndrews & Woodson,
171 N.H. 214, 218 (2018). RSA 458-A:13, I, provides:

I. Except as otherwise provided in RSA 458-A:15, a court of this
state which has made a child-custody determination consistent
with RSA 458-A:12 or RSA 458-A:14 has exclusive, continuing
jurisdiction over the determination until:

(a) A court of this state determines that neither the child, nor
the child and one parent, nor the child and a person acting as a
parent have a significant connection with this state and that
substantial evidence is no longer available in this state

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concerning the child’s care, protection, training, and personal
relationships; or

(b) A court of this state or a court of another state determines
that the child, the child’s parents, and any person acting as a
parent do not presently reside in this state.

The use of the phrase “[a] court of this state” in subsection (a) makes it clear
that the original decree state is the sole determinant of whether jurisdiction
continues under that subsection. See In the Matter of Yaman & Yaman, 167
N.H. 82, 88 (2014). A party seeking to modify a custody determination under
that subsection must obtain an order from the original decree state stating that
it no longer has jurisdiction. See id.

New Hampshire initially had exclusive, continuing jurisdiction over this
matter because a court of this state made a child custody determination, and
Father resides here. See RSA 458-A:13, I. Mother argues, however, that New
Hampshire no longer maintains exclusive, continuing jurisdiction because the
trial court relinquished jurisdiction over this matter pursuant to the terms of
the relocation order. See id.

The interpretation of a court order is a question of law, which we
review de novo. In the Matter of Sheys & Blackburn, 168 N.H. 35, 39
(2015). In construing a court order, we look to the plain meaning of the words
used in the document. Id. We construe subsidiary clauses so as not to conflict
with the primary purpose of the trial court’s decree. Id. at 39-40. As a general
matter, a court decree or judgment is to be construed with reference to the
issues it was meant to decide. Id. at 40.

The relocation order granted Mother permission to move to Maine with
the children, and states in part: “Both Parties agree that New Hampshire shall
maintain jurisdiction over this matter during the Mother’s relocation and while
she resides in Maine for a minimum of 6 months to one year.” We are
unpersuaded that this language provides that the trial court relinquished
jurisdiction. The relocation order does not provide that New Hampshire loses
jurisdiction over this matter after one year; rather, it sets a minimum
timeframe during which the court will not relinquish jurisdiction. Further, the
relocation order neither references RSA 458-A:13, which provides the
requirements for New Hampshire courts to relinquish jurisdiction over child
custody determinations, nor does it make the requisite findings under that
statute. Accordingly, we conclude that the relocation order does not provide
that the court loses exclusive, continuing jurisdiction over this matter.

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B. Inconvenient Forum

A court with exclusive, continuing jurisdiction may decline to exercise
jurisdiction if it determines that it is an inconvenient forum under the
circumstances and that a court of another state is a more appropriate forum.
See RSA 458-A:18, I; McAndrews, 171 N.H. at 219. RSA 458-A:18, II provides
a list of factors that the trial court must consider in conducting its
inconvenient forum analysis. See McAndrews, 171 N.H. at 217.

Mother argues that the trial court failed to properly weigh the evidence
and consider all relevant facts when it considered the factors in RSA 458-A:18,
II(b), (d), (e), (f), (g), and (h). The trial court’s decision to retain or relinquish a
child custody case on inconvenient forum grounds falls within the court’s
discretion. See McAndrews, 171 N.H. at 218. We will overturn the trial court’s
decision only if we find an unsustainable exercise of discretion. Id. This
standard of review requires that Mother demonstrate that the court’s ruling
was clearly untenable or unreasonable to the prejudice of her case. See id.
When a party argues that a court unsustainably exercised its discretion
because its decision was not supported by the evidence, we review only
whether the record establishes an objective basis sufficient to sustain the
discretionary judgment made, and we will not disturb the trial court’s
determination if it could reasonably be made. See In the Matter of Choy &
Choy, 154 N.H. 707, 713 (2007). We address the challenged factors in turn.

RSA 458-A:18, II(b) provides that the trial court, when conducting
its inconvenient forum analysis, must consider “[t]he length of time the
child has resided outside this state.” The trial court considered this
factor and found that, while the children have lived in Maine for “the past
several years,” “[t]hey have maintained regular contact with New
Hampshire by visiting the father and family located in New Hampshire on
a regular basis.” The record supports that the children have resided in
Maine for several years, and Mother concedes that “[Father] could see the
children in New Hampshire” as of April 2023. Thus, the record and
Mother’s concession support the trial court’s findings on this factor.

RSA 458-A:18, II(d) provides that the trial court must consider
“[t]he relative financial circumstances of the parties.” The trial court
considered this factor and concluded that Mother “is financially better
able to absorb the financial cost” of litigating this matter in another state
than Father. The trial court noted Mother’s acknowledgement that she
makes approximately $500,000 per year and that Father makes
approximately $125,000 per year. There is an objective basis in the
record for those figures, and Mother does not dispute the accuracy of
those figures on appeal. Accordingly, Mother has failed to demonstrate
that the trial court erred.

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RSA 458-A:18, II(e) provides that the trial court must consider
“[a]ny agreement of the parties as to which state should assume
jurisdiction.” Mother argues that the December 2021 stipulation was an
agreement between the parties that New Hampshire would relinquish
jurisdiction after one year. The trial court considered and rejected this
argument, and — as explained above — we agree with the court’s
conclusion that the stipulation does not establish that the parties agreed
to relinquish jurisdiction in New Hampshire.

Lastly, RSA 458-A:18, II(f), (g), and (h) provide that the trial court
must consider “[t]he nature and location of the evidence required to
resolve the pending litigation, including testimony of the child”; “[t]he
ability of the court of each state to decide the issue expeditiously and the
procedures necessary to present the evidence”; and “[t]he familiarity of
the court of each state with the facts and issues in the pending
litigation.” The trial court considered all these factors. The court noted
that it is being asked to interpret and modify an agreement that it
approved, that New Hampshire law applies to the agreement, and that if
witnesses need to be called from Maine, they could testify via video link.
The court also found that Mother submitted no evidence supporting the
assertion that litigating this dispute in New Hampshire would cause
unnecessary delay. Further, while Mother asserts that she would face
procedural burdens to subpoena witnesses in Maine if the case must be
litigated in New Hampshire, as the trial court observed, the same
problem arises if the case were litigated in Maine and the parties sought
to subpoena witnesses in New Hampshire.

Therefore, upon our review of the trial court’s order, the written
arguments of the parties, and the record submitted on appeal, we
conclude that the trial court did not unsustainably exercise its discretion
when it declined to rule that New Hampshire is an inconvenient forum
and that Maine is a more appropriate forum pursuant to RSA 458-A:18.
We have considered Mother’s remaining arguments, and we conclude
that they do not warrant further discussion. See Vogel v. Vogel, 137 N.H.
321, 322 (1993); Sup. Ct. R. 25(8). Accordingly, we affirm.

Affirmed.

MACDONALD, C.J., and HANTZ MARCONI, DONOVAN, COUNTWAY, and
GOULD, JJ., concurred.

Timothy A. Gudas,
Clerk

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