The New Hampshire Supreme Court affirmed a Circuit Court ruling that the state retains exclusive jurisdiction over a child custody matter between unmarried parents, despite one parent's relocation to another state with the children.
In *In the Matter of Taylor Coyne and Ashley Blanchfield*, decided Oct. 30, 2025, the high court rejected Ashley Blanchfield's appeal challenging the Circuit Court's determination that New Hampshire maintains continuing jurisdiction over custody arrangements for her two children with Taylor Coyne.
The case centers on a jurisdictional dispute that arose after Blanchfield relocated to Maine with the couple's two children, who were born in 2020. The unmarried parents had initially agreed to the relocation through a joint stipulation filed in December 2021.
The original agreement explicitly addressed jurisdictional concerns. The stipulation stated that "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." Circuit Court Judge Pendleton approved this relocation order in December 2021, allowing Blanchfield to move to Maine with the children for work purposes.
Following the approved relocation, the New Hampshire court continued to exercise its authority over the family's legal matters. In January 2023, the court entered both a final uniform support order and a final parenting plan governing the custody arrangement between the parents.
The jurisdictional conflict emerged in August 2023 when Blanchfield filed an affidavit and request with the Maine District Court to register what she characterized as a "foreign child custody order" under Maine's Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). In her petition, Blanchfield claimed that Maine had jurisdiction to modify the custody order because the New Hampshire court "no longer has exclusive, continuing jurisdiction" or that Maine "would be a more convenient forum."
Blanchfield's Maine petition sought two primary forms of relief: she moved to hold Coyne in contempt under the final parenting plan and requested modifications to the existing custody arrangement. However, Coyne contested Maine's authority to hear these matters, filing a motion to dismiss the petition on jurisdictional grounds.
Coyne argued that the Maine court lacked jurisdiction over the final parenting plan because New Hampshire maintains exclusive, continuing jurisdiction over the case. This position aligned with the parties' original 2021 stipulation explicitly agreeing that New Hampshire would retain authority over custody matters.
After conducting a hearing on the jurisdictional question, the Maine District Court sided with Coyne's position and granted the motion to dismiss. The Maine court acknowledged that it lacked authority to proceed with Blanchfield's requested modifications and contempt proceedings.
Undeterred by the Maine court's dismissal, Blanchfield appealed the New Hampshire Circuit Court's assertion of continuing jurisdiction to the New Hampshire Supreme Court. Her appeal challenged Judge Pendleton's determination that New Hampshire retained exclusive authority over the custody matter.
The Supreme Court resolved the case through a written order rather than a full opinion, citing Supreme Court Rule 20(3), which allows the court to dispose of cases based on written submissions when oral argument is unnecessary. After reviewing the written arguments and the trial court record, the justices determined that the Circuit Court correctly maintained its jurisdictional authority.
The affirmation reinforces New Hampshire's position as the proper forum for ongoing custody disputes between Coyne and Blanchfield. The ruling validates the lower court's interpretation that the parties' explicit agreement to maintain New Hampshire jurisdiction, combined with the state's role in approving the initial relocation and establishing the final custody arrangements, creates continuing authority over future modifications.
The decision highlights the importance of jurisdictional agreements in interstate custody cases. When parents explicitly agree that a particular state will maintain authority over custody matters during relocations, courts will generally honor those agreements even when circumstances change.
The case also demonstrates how the UCCJEA operates to prevent conflicting custody orders between states. The Maine court's dismissal and New Hampshire's jurisdictional retention work together to ensure that only one state exercises authority over the family's custody arrangements, preventing the confusion and potential conflicts that could arise from parallel proceedings.
For Blanchfield, the ruling means that any future requests for custody modifications or enforcement actions must be filed in New Hampshire courts rather than Maine, despite her residence there with the children. The decision preserves the stability of the existing custody framework while respecting the parties' original jurisdictional agreement.
The case serves as a reminder to parents considering interstate relocations to carefully consider jurisdictional provisions in their custody agreements, as these determinations can have lasting implications for where future legal proceedings must occur.