Gail Rosier v. Jeffrey Strobel

In light of Turner v. Rogers, 564 U.S. 431 (U.S. 2011), what minimum procedural safeguards are required to ensure due process for incarcerated and indigent obligors who face child support proceedings under the Uniform Interstate Family Support Act (“UIFSA”) and the possibility of contempt and imprisonment?

In determining whether to register and enforce a foreign order, do principals of full faith and credit bar a state from considering due process, subject matter jurisdiction or fraud upon the court if those issues were not actually raised or fully and fairly litigated in the foreign state?

The UIFSA provides that an obligor may seek to vacate the registration of a foreign support order if he or she establishes “a defense under the law of this state to the remedy sought.” Does this mean that a foreign support order may not be enforced via contempt and imprisonment if the underlying obligation is considered an ordinary money debt per the laws and constitution of the registering state? Stated differently, is a registering state obligated to apply child support remedies that would not be available had the order originated in the registering state?