Florida/Georgia Personal Injury & Workers Compensation

...s of this act. § 61.506, Fla. Stat (2005). Section 61.514, Florida Statutes (2005), of the UCCJEA, unequivocally limits jurisdiction to determine initial custody matters (except for temporary emergency matters) to the "home state" of the child, and section 61.503(7) defines "home state," in pertinent part, as "the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding." Section...

...§ 2265 have been satisfied, and North Dakota's domestic violence protective order was entitled to full faith and credit. However, since the protective order affected Florida's initial custody determination, the protective order is also governed, in part, by the UCCJEA. See § 61.503(4), Fla....

...[2] "Home state" is defined in relevant part as "the state in which a child lived with a parent or person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding.... A period of temporary absence of any of the mentioned persons is part of the period." § 61.503(7), Fla....

...On the date that the paternity action was commenced in this case, Florida was not the "home state" of the child because the child had not lived in Florida for six consecutive months prior to the commencement of the paternity action in November 2003. § 61.503(7), Fla....

...rent continues to live in this state. . . . *1239 "`Home state' means the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding." § 61.503(7)....

...state. See § 61.514, Fla. Stat. (2007). "Home state" is defined as "the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding." § 61.503(7), Fla....

...tion to enter orders concerning visitation. Indeed, even for the general purposes of the Uniform Child Custody Jurisdiction and Enforcement Act, the term “child” is defined as meaning “an individual who has not attained 18 years of age.” See § 61.503(2), Fla....

...See § 61.514(1)(a), Fla. Stat. (2008) (stating that "a court of this state has jurisdiction to make an initial child custody determination" where "[t]his state is the home state of the child on the date of the commencement of the proceeding"); see also § 61.503(7), Fla....

...[2] "Home state" is defined in relevant part as "the state in which a child lived with a parent or person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding.... A period of temporary absence of any of the mentioned persons is part of the period." § 61.503(7)....

...father's affidavit assert that the child had lived with him in another state for six consecutive months prior to the initial filing. This record supports the trial court's exercise of jurisdiction pursuant to sections 61.514(1)(a), 61.514(1)(b), and 61.503(7), Florida Statutes....

...mencement of the proceeding and the child is absent from this state but a parent ... continues to live in this state; (b) A court of another state does not have jurisdiction under paragraph (a) ... § 61.514(1), Fla. Stat. "Home state" is defined in section 61.503(7), Florida Statutes, as: "the state in which a child lived with a parent ....

...However, the father's actions were primarily defensive, consistent with his right to participate in this proceeding under the UCCJEA without waiving an objection to personal jurisdiction on the issues of child support or other monetary obligations. A "child custody determination" under section 61.503(3), Florida Statutes (2008), is an order providing for, among other things, the "physical custody" and "visitation with respect to a child"; that "term does not include an order relating to child support or other monetary obligation of...

“child custody proceeding” within the meaning of section 61.503(4), Florida Statutes (2013),[N,2] it became

...to immediate monetary relief or child custody in family law matters." (Emphasis added.) A "child custody proceeding" is defined as one in which legal custody, physical custody, residential care, or visitation with respect to a child is at issue. See § 61.503(4), Fla....

...c violence. We reverse and remand. Although the order on appeal is non-final, it is reviewable under Florida Rule of Appellate Procedure 9.130(a)(3)(C)(iii) (allowing appeal of non-final orders determining "child custody in family law matters"). See § 61.503(4), Fla....

...The Petitioner did not file his action in Sarasota County, Florida, until December 10, 2010. Florida was not the “home state” of the child “... for at least six (6) consecutive months immediately before the commencement of a child custody proceeding,” as required by F.S. 61.503(7)....

...ter of law. See N.W.T. v. L.H.D., 955 So.2d 1236, 1238 (Fla. 2d DCA 2007). The UCCJEA is a jurisdictional act that governs subject matter jurisdiction over child custody matters. Id.; see also § 61.502 (stating the general purposes of the UC-CJEA). Section 61.503(4) defines a “child custody proceeding” as “a proceeding in which ......

...visitation with respect to a child is an issue.” Section 61.514 “unequivocally limits jurisdiction to determine initial custody matters (except for temporary emergency matters) to the ‘home state’ of the child.” Arjona v. Torres, 941 So.2d 451, 454 (Fla. 3d DCA 2006). “Home state” is defined in section 61.503(7) as “the state in which a child lived with a parent or a person acting as a parent for at least [six] consecutive months immediately before the commencement of a child custody proceeding.” Section 61.514(1) states as follows: (1) Except as otherwise provided in s....

...The UCCJEA defines a child’s “home state” as “the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding.... A period of temporary absence of any of the mentioned persons is part of the period.” § 61.503(7), Fla....

...d lived in Florida for 6 consecutive months. By definition, however, “home state” means “the state in which a child lived with a parent ... for at least 6 consecutive months immediately before the commencement of a child custody proceeding.” § 61.503(7), Fla....

...On May 8, 2006, the children were in Turkey and had been in Turkey for seven weeks. Two months prior to that time, however, they lived in Florida with both parents. Under the definition of “home state,” a period of temporary absence is to be considered as part of the consecutive, six-month period. See § 61.503(7), Fla....

...l child” because it awarded long-term child support pursuant to section 743.07(2). We disagree. Jonathan is not a child for purposes of the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) because he is over the age of eighteen. See § 61.503(2), Fla....

...determination" as a "judgment, decree, or other order of a court providing for the legal custody, physical custody, residential care, or visitation with respect to a child. The term includes a permanent, temporary, initial, and modification order." § 61.503(3)....

...Mannino was able to defeat this petition in March 2006 with a meritorious motion to dismiss. [5] Sgt. Mannino's claim that the court in Florida did not have subject matter jurisdiction over child custody matters at the time of the dissolution judgment presents an arguable issue. See § 61.503(7) ("`Home state' means the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding."); N.W.T....

...The Uniform Child Custody Jurisdiction Act "applies to paternity actions when custody is an issue." Wilson v. Zambito, 773 So.2d 581, 582 (Fla. 4th DCA 2000). The child has resided in Texas for over three years with petitioner, a "person acting as a parent" within the meaning of section 61.503(13), Florida Statutes (2004), so there is no jurisdiction under section 61.514(1)(a)....

...Lande, 2 So.3d 378, 381 (Fla. 4th DCA 2008). The statute defines “home state” as “the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding.” § 61.503(7), Fla....

...Johnson’s motion to dismiss put the Florida court’s jurisdiction over their child at issue. Thus, the first determination the trial court had to make was whether Florida had jurisdiction over the child pursuant to the UCCJEA. See § 61.508. 8 The child’s “home state” determines jurisdiction over the child. Section 61.503(7) defines “home state” as “the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding.” But the record conclusively shows that at the commencement of these proceedings — either Mrs....

...514, Fla. Stat. (2016); Ga. Code § 19-9-61 (2016), defined as “the state in which a child lived with a parent or a person acting as, a parent for at least 6 consecutive months immediately before the commencement of a' child custody proceeding.” § 61.503(7), Fla....

...ments of another state when applicable. See id. Here, the trial court properly enforced the Colorado order determining visitation. Since the Colorado order was a final judgment and emanated from a “child custody proceeding” within the meaning of section 61.503(4), Florida Statutes (2013), 2 it became enforceable in Florida pursuant to the Full Faith and Credit Clause as well as section 61.526, Florida Statutes....

...61.502(1), Fla. Stat. (2010). Under the UCCJEA, a “child custody determination” means “a judgment, decree, or other order of a court providing for the legal custody, physical custody, residential care, or visitation with respect to a child.” § 61.503(3), Fla....

...on of an individual. Id. A “ ‘[cjhild custody proceeding’ means a proceeding in which legal custody, physical custody, residential care, or visitation with respect to a child is an issue. The term includes a proceeding for ... paternity....” § 61.503(4), Fla....

...lephonically included the New York court. No testimony or evidence was presented at the hearings. Father argued 2 “claims a right to a child-custody determination under the laws of this state.” § 61.503(13)(a)-(b), Fla....

...ons because from birth to relocation, the child lived in Florida with both Father and Mother. The child was less than six months old, and the child’s home state is where the child lived from birth with a parent or person acting as a parent. See § 61.503(7), Fla....

...In the case of a child younger than 6 months of age, the term means the state in which the child lived from birth with any of the persons mentioned. A period of temporary absence of any of the mentioned persons is part of the period. § 61.503(7), Fla....

...While the UCCJEA does not specifically define “parent,” the definition of “person acting as a parent” includes a person other than a “parent” who 5 “claims a right to a child-custody determination under the laws of this state.” § 61.503(13)(a)-(b), Fla....

...ons because from birth to relocation, the child lived in Florida with both Father and Mother. The child was less than six months old, and the child’s home state is where the child lived from birth with a parent or person acting as a parent. See § 61.503(7), Fla....

...At all material times, she stated, the family had lived in the UAE. She challenged the circuit court's initial acquisition and continued assertion of subject matter jurisdiction over the children, arguing that Florida was never the minor children's "home state" under Florida's UCCJEA. See § 61.503(7), Fla....

...child was not subject to the jurisdiction of the Florida courts"). -5- Ms. Scudder, there was no evidence that could have established a Florida residency for the parties or their children under sections 61.021, 61.503(4), and 61.514....

...n February 10, 2010. An order closing the file was entered on February 2, 2011. Although a proceeding for divorce is included within the definition of "child custody proceeding” under the Uniform Child Custody Jurisdiction and Enforcement Act, see § 61.503(4), Fla....

...Jurisdiction attaches when ... a *547 child is taken into the custody of the Department." § 39.40(2), Fla. Stat. (1997). Furthermore, the Uniform Child Custody Jurisdiction and Enforcement Act [UCCJA], which applies to dependency proceedings, see § 61.503(4), Fla....

...(2005)). 2 The father evidently had filed a child custody proceeding in Arizona. 2 subject-matter jurisdiction for three reasons: (1) the mother did not file a motion regarding a “child custody proceeding” as defined by section 61.503(4), Florida Statutes (2013); (2) Florida was not the “home state” of the child; and (3) Arizona had already begun proceedings “in substantial conformity with the UCCJEA.” The mother appeals this order. We discuss the trial court’s determinations sequentially. Appellate Analysis and Disposition “Child Custody Proceeding” Section 61.503(4), Florida Statutes (2013), states: (4) “Child custody proceeding” means a proceeding in which legal custody, physical custody, residential care, or visitation with respect to a child is an issue....

...parental rights, and protection from domestic violence, in which the issue may appear. The term does not include a proceeding involving juvenile delinquency, contractual emancipation, or enforcement under ss. 61.524-61.540. § 61.503(4), Fla....

...of jurisdiction to domesticate a foreign custody order. 3 The “Home State” Rule Likewise, the trial court also incorrectly applied the “home state” rule to the mother’s petition to domesticate the NY Order. Section 61.503(7), Florida Statutes (2013), provides: (7) “Home state” means the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding....

...In the case of a child younger than 6 months of age, the term means the state in which the child lived from birth with any of the persons mentioned. A period of temporary absence of any of the mentioned persons is part of the period. § 61.503(7), Fla....

...of Children & Families, 70 So. 3d 749, 753 (Fla. 4th DCA 2011). In the present case, the record establishes that the trial court acquired, and had continuing, jurisdiction over the case and children because Florida is the children’s home state under the UCCJEA. Section 61.503 (7) defines “home state” as: (7) “Home state” means the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a ch...

...an inconvenient forum under the circumstances and that a court of another state is a more appropriate forum. The issue of inconvenient forum may be raised upon motion of a party, the court's own motion, or a request by another court. Under section 61.503(15), Puerto Rico is a “state” for purposes of the UCCJEA as enacted in Florida, though Puerto Rico itself has not enacted the UCCJEA....

...Although we are comfortable that non-final orders determining visitation in family law cases are reviewable under Florida Rule of Appellate Procedure 9.130(a)(3)(C)(iii) (allowing appeal of non-final orders determining "child custody in family law matters") see also § 61.503(3) Fla....

...Consequently, the family court no longer has jurisdiction over him, rendering the portion of the challenged order requiring him to participate moot. See Ford v. Ford, 153 So. 3d 315, 317 (Fla. 4th DCA 2014); Hardman v. Koslowski, 135 So. 3d 434, 436 (Fla. 1st DCA 2014); see also § 61.13(2), Fla. Stat. (2022); § 61.503(2), Fla....

commencement of a child custody proceeding." § 61.503(7). A period of temporary absence is considered

...)(3)(C)(iii)b. “A ‘child custody proceeding’ is defined as one in which legal custody, physical custody, residential care, or visitation with respect to a child is at issue.” Hickey v. Burlinson, 33 So. 3d 827, 829 (Fla 5th DCA 2010) (citing § 61.503(4), Fla....

...2d 451, 454 (Fla. 3d DCA 2006). “Home state” is defined as “the state in which a child lived with a parent or a person acting as a parent for at least [six] consecutive months immediately before the commencement of a child custody proceeding.” § 61.503(7), Fla. Stat.4 In computing the requisite six-month period, “[a] ....

...residential care, or visitation with respect to a child is an issue. The term includes a proceeding for divorce, separation, neglect, abuse, dependency, guardianship, paternity, termination of parental rights, and protection from domestic violence . . . . § 61.503(4), Fla....

...61.514(1)(a) or (b)." [5] Because the record clearly establishes that both parties and their child lived in Florida for at least six months prior to the commencement of the Florida proceedings, Florida was the child's home state at the time the Florida proceedings commenced. See § 61.503(7)....

...personal relationships; or 1 A child’s “home state” is “the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding.” § 61.503(7), Fla....

...1st DCA 2014) (holding that a trial court loses subject matter jurisdiction over child custody and visitation determinations when a child turns eighteen). Only one of Mr. Kessinger’s children remains a minor and that child lives with Ms. Kessinger in Georgia. § 61.503(2), Fla....

...lly from the harmful effects of their wrongful removal or retention and to establish procedure to ensure their prompt return to the State of their habitual residence.’” This affirmance does not, however, extend to the support determinations. See § 61.503(3), Fla....

...ontinues to live in this state.... *1239 “ ‘Home state’ means the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding.” § 61.503(7)....

...§ 61.514(1)(a), Fla. Stat. (2022); see also § 61.506, Fla. Stat. (2022) (defining foreign courts to include courts of foreign countries). The “initial determination” is “the first child custody determination concerning a particular child.” § 61.503(8), Fla. Stat. (2022). The “home state” is “the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding.” § 61.503(7), Fla....

...§ 61.514(1)(a), Fla. Stat. (2022); see also § 61.506, Fla. Stat. (2022) (defining foreign courts to include courts of foreign countries). The “initial determination” is “the first child custody determination concerning a particular child.” § 61.503(8), Fla. Stat. (2022). The “home state” is “the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding.” § 61.503(7), Fla....

...2d 451, 454 (Fla. 3d DCA 2006). “Home state” is statutorily defined as “the state in which a child lived with a parent or a person acting as a parent for at least [six] consecutive months immediately before the commencement of a child custody proceeding.” § 61.503(7), Fla....

...absence, within [one] year immediately before the commencement of a child custody proceeding; and (b) Has been awarded a child-custody determination by a court or claims a right to a child-custody determination under the laws of this state. § 61.503(13), Fla....

...on persons outside this state must be made pursuant to s. 61.509 [formerly § 61.1312.],” which is part of the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), section 61.501-.542, Florida Statutes (2003). “Child custody proceedings,” defined in section 61.503(4) of the UCCJEA, include proceedings for dependency or paternity in which the issue of legal or physical custody may appear....

...Torres , 941 So. 2d 451 , 454 (Fla. 3d DCA 2006). "Home state" is defined as "the state in which a child lived with a parent or a person acting as a parent for at least [six-]consecutive months immediately before the commencement of a child custody proceeding." § 61.503(7), Fla....

...] jurisdiction ... unless the proceeding has been terminated or is stayed by the court of the other state because a court of this state is a more convenient forum under s. 61.520."). We agree that, under the broad statutory definition promulgated in section 61.503(4), Florida Statutes (2018), the temporary emergency proceeding constituted an earlier-initiated child custody proceeding....

...The trial court terminated the parental rights of both parents, however, only the mother has appealed. Section 3402(g), California Family Code (2018), contains an identical definition. The UCCJEA defines "abandoned" as "left without provision for reasonable and necessary care or supervision." § 61.503(1), Fla. Stat. (2018) ; Cal. Fam. Code § 3402 (a) (2018). Section 61.503(4), Florida Statutes (2018), defines "[c]hild custody proceeding" as "a proceeding in which legal custody ......

...Torres , 941 So. 2d 451 , 454 (Fla. 3d DCA 2006). "Home state" is defined as "the state in which a child lived with a parent or a person acting as a parent for at least [six-]consecutive months immediately before the commencement of a child custody proceeding." § 61.503(7), Fla....

...] jurisdiction ... unless the proceeding has been terminated or is stayed by the court of the other state because a court of this state is a more convenient forum under s. 61.520."). We agree that, under the broad statutory definition promulgated in section 61.503(4), Florida Statutes (2018), the temporary emergency proceeding constituted an earlier-initiated child custody proceeding....

...The trial court terminated the parental rights of both parents, however, only the mother has appealed. Section 3402(g), California Family Code (2018), contains an identical definition. The UCCJEA defines "abandoned" as "left without provision for reasonable and necessary care or supervision." § 61.503(1), Fla. Stat. (2018) ; Cal. Fam. Code § 3402 (a) (2018). Section 61.503(4), Florida Statutes (2018), defines "[c]hild custody proceeding" as "a proceeding in which legal custody ......

...On September 26, 2007, the trial court entered its order determining jurisdiction. In that order, the court determined that Florida was the home state of Nahomy for purposes of the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). See § 61.503(7), Fla....

the Florida or the South Carolina statutes. See § 61.503(4) (“ ‘Child custody proceeding’ means a proceeding

...4th DCA 2015) (citation omitted). “Under the UCCJEA, jurisdictional priority lies in the child’s home state.” Barnes, 124 So. 3d at 995 (citation omitted). Within Florida’s codification of the UCCJEA, that jurisdictional priority arises from sections 61.503(7) and 61.514(1)(a), Florida Statutes (2015). Section 61.503(7) provides, “‘Home state’ means the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding. In the case of a child younger than 6 months of age, the term means the state in which the child lived from birth with any of the persons mentioned.” § 61.503(7), Fla....

...e state. § 61.514(1)(a), Fla. Stat. (2015). Florida remained the child’s home state because within a portion of the six months before the grandmother’s petition, the child was younger than six months of age, and had lived in Florida from birth. § 61.503(7), Fla....

...Because this order grants the Father visitation rights, we have jurisdiction. See Fla. R.App. P. 9.130(a)(3)(c)(iii) (granting appellate jurisdiction over non-final orders that determine “the right to immediate monetary relief or child custody in family law matters”); § 61.503(4), Fla....

...61.520; or (2) A court of this state or a court of the other state determines that the child, the child’s parents, and any person acting as a parent do not presently reside in the other state. A “child custody determination,” for the purpose of section 61.516, is defined in section 61.503(3), Florida Statutes, as follows: “Child custody determination” means a judgment, decree, or other order of a court providing for the legal custody, physical custody, residential care, or visitation with respect to a child....

...y person acting as a parent do not presently reside in” Kentucky. “Person acting as a parent” 8 includes a person, other than a parent, who “[h]as been awarded a child-custody determination by a court.” § 61.503(13)(b), Fla....

...3 We in turn also reject the trial court’s conclusion to the contrary in its “Order on Motion for Exclusive Jurisdiction.” That order indicated that “there is no person ‘acting as a parent’ in Kentucky as per Chapter 61.516(2) Fl. St. and Fl. St. 61.503(13).” As stated above, this conclusion is inaccurate, because the Grandmother is a person “acting as a parent,” as section 61.503(13) defines that term....

...Section 61.518(1), Florida Statutes (2015), provides that "[b]efore a child custody determination is made under this part, notice and an opportunity to be heard . . . must be given to . . . any parent whose parental rights have not been previously terminated." Section 61.503(3) defines "[c]hild custody determination" as "a judgment, decree, or other order of a court providing for the legal custody, physical custody, residential care, or visitation with respect to a child....

...ild lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding. . . . A period of temporary absence of any of the mentioned persons is part of the period.” § 61.503(7), Fla. Stat....

...(emphasis added). “‘Child custody proceeding’ means a proceeding in which legal custody, physical custody, . . . or visitation with respect to a child is an issue,” and “includes a proceeding for divorce, separation, . . . abuse, . . . and protection from domestic violence, in which the issue may appear.” § 61.503(4), Fla....

...“‘Child custody determination’ means a judgment, decree, or other order of a court providing for the legal custody, physical custody, residential care, or visitation with respect to a child. The term includes a permanent, temporary, initial, [and/or] modification order.” § 61.503(3), Fla....

..."foreign judgments," which it defines as a "judgment, decree, or order of a court of any other state or of the United States," see § 55.502(1), and "out of country foreign judgments" that are obtained from "foreign states," see § 55.602. See also § 61.503(15), Fla....

...standard of review: [t]o the extent the trial court's order is based on factual proceeding and the child is absent from this state but a parent or person acting as a parent continues to live in this state. . . . “Home state” is defined in section 61.503(7), and means the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding....

...Here, there is no request for a child custody determination in the pleadings as Florida, admittedly, is not the home state of the child. The term “child custody determination” under the UCCJEA specifically excludes an order relating to child support or other monetary obligation of an individual. See § 61.503(3), Fla....

...Section 61.514(1)(a) provides Florida has jurisdiction over a child custody action if Florida was the home state of the minor child on the date the petition was filed or was the home state of the minor child within six months before the petition was filed. See § 61.514(1)(a), Fla. Stat. Section 61.503(7) defines a minor child’s home state as “the state in which a child lived with a parent or a person acting as a parent for at least 6 consecutive months immediately before the commencement of a child custody proceeding.” § 61.503(7), Fla. Stat. Section 61.503(7) further states 4 a “period of temporary absence” is included in the relevant six-month period, but a period of temporary absence is not defined. Florida courts have interpreted t...

...termination" as a "judgment, decree, or other order of a court providing for the legal custody, physical custody, residential care, or visitation with respect to a child. The term includes a permanent, temporary, initial, and modification order." § 61.503(3)....

...“The UCCJEA unequivocally limits jurisdiction to determine initial custody matters ... to *586 the child’s ‘home state.’ ” Arjona v. Torres, 941 So.2d 451, 454 (Fla. 3d DCA 2006). The question of whether Florida is a child’s “home state” depends on the facts of each case. Section 61.503(7), Florida Statutes (2012), defines “Home state” as “the state in which a child lived with a parent ......

...(“UCCJEA”) applies. We disagree. The UCCJEA is “a jurisdictional act which controls custody disputes.” Arjona v. Torres, 941 So. 2d 451, 454 (Fla. 3d DCA 2006) (emphasis omitted). And it only applies where custody is at issue. See § 61.503(4), Fla....

...other person any right to time-sharing, residential care, kinship, or custody, as provided under state law." The Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) defines "child" as "an individual who has not attained 18 years of age." § 61.503(2)....