Refusal to Register a Michigan Divorce Decree to Secure Custody Proper Where that Decree Had Been Subsequently Modified.

 In Morrison v. Morrison, the Virginia Court of Appeals, in a published opinion, upheld the circuit court’s refusal to register and enforce a 2003 Michigan divorce decree in the Commonwealth giving mother custody of parties’ child.  While disagreeing with the lower court’s reasoning, the Court held that the refusal was proper, given that the 2003 decree had been subsequently modified in 2008. The Court also refused to consider the father’s attempt to invoke the fugitive disentitlement doctrine on appeal, holding the doctrine to be inapplicable to the facts of the case.