In re R.L.

Cynthia C. and Gerardo L. appeal from orders terminating parental rights to their daughter, R.L. Gerardo contends the jurisdictional and dispositional findings and orders, and all subsequent orders, must be reversed because the juvenile court did not have home state jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act, Family Code section 3400 et seq. (UCCJEA). He also contends the orders must be reversed because he did not receive notice of the proceedings pursuant to the Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters (Nov. 15, 1965, 20 U.S.T. 361, T.I.A.S. No. 6638) (the Hague Service Convention or Convention). Cynthia joins in Gerardo’s arguments to the extent they inure to her benefit, but raises no other issues.

The facts of this case present an interesting issue concerning “home state” jurisdiction, as defined by the UCCJEA. R.L. was born in a hospital in San Diego County. Her mother, Cynthia, is a United States citizen. For approximately three years prior to R.L.’s birth, Cynthia did not have a permanent residence. She alternated her time between Tijuana and Las Vegas, but had been…