decided to leave the state of missouri around and then if you're maybe going into the yeah but a whole side of things but really when we're looking at jurisdiction we're talking about personal jurisdiction  section you're indicating that she submitted herself with the jurisdiction of the illinois part of the of the agreement and so personal jurisdictions establish its subject matter jurisdiction then the trial court  then is subject matter jurisdiction and she isn't in a lexus is indicating that the u c c j p s a specifically provides for subject matter jurisdiction under or separate circumstances none of pump here if the illinois constitution provided for subject matter jurisdiction in this case by indicating that circuit courts have original compare her completely and i don't think there's any question the so what is the case authority that tells us that your position is the correct position while we start with the constitution illinois it is a limitation on the exercise of fiction and unfortunately our supreme court when it jurisdiction you can do anything you want no worse you don't have to follow these restrictions and you can do it so jurisdiction fenosa the ability to make a dish thirteen no one says you can object to a judgment within thirty days or even two for the one where we get into the process onset of that also so none of these things were done in terms of child support the provision of medical insurance for the child in the line unless some benefits of judge walk once original order were accepted enter the orders she answered i think we still are within every man to see if you see c j applies because we've got the improper removal we've got cited any cases is because there are ten there what we learn from those books hoda is the law is binding on everyone is fighting and everybody here all the authorities case she if you will enjoy it all the benefits and now wants to complain about the benefits she got in her judgment that the issue really so no she could argue spoken to with the out search about this case as it deals with such matters jurisdiction to begin with there is no contention here that's been made by either the petitioner or at any point that minor child allow her to head out that jurisdiction nor are you talking personal jurisdiction over the child now as opposed to subject matter jurist i'm talking subject matter d'oeuvres the action the court a personal jurisdiction to enter into the well so if you're talking about subject matter jurisdiction you're talking about jurisdiction over a matter and that would be a custody issue here correct that's that's that's correct and that would deal with the issue here of the joint parenting again there are severe there are contacts where you consider a child's home state or significant context would actually consider or there could be if there has been no other exception as far as the urgency jurisdiction parties and done for another reason somebody confessed that after a period of time and stated that the subject was void so the question here of lot of being an actual matter that subject matter jurisdiction  over a minor child is the term and by where the child's home state is and that's that shit was enacted mainly for circumstances such as these where you're trying to determine well if the child if there was a way you know where's the child at this moment because people are are moving around quite often at the end of the day you're looking at the best interests of the child i don't believe that the supreme that the constitution is going to matter subject matter jurisdiction is the right to hear a class of cases and that's something that things can be had and i think that my mr wilson has mentioned this that the legislature has given course the right to hear church actions and i believe that this is something that isn't going to be covered by bell which talks about irregularities and collateral attacks many of the cases that i've as far as alexander for example speak about a matter where there was subject matter jurisdiction at one time and then at some point later ron as in the case a pointer they feel that there was some fraud which happened at a point of time years earlier and now are using it as a collateral attack to try to say ok we didn't have such matters jurisdiction the other cases talked about where there's not an affidavit for reconcilable differences and that's an issue that because of that people argue there's no subject matter jurisdiction this goes the something more fundamental and this goes towards the end the court has subject matter jurisdiction over a party when that party has not had contacts with this state as for actual jurisdictional issue and then makes a determination as far as where the actual jurisdiction should lie and they actually go through the process with the u c c j in that case to determine which state has the significant contests that's a case where the court determined well if there isn't if there is a child doesn't actually if illinois in the whole state is there significant concepts however you still have an issue here were available toyota is being talked about as far as well the court has jurisdiction here this matter and then the court goes into the application for the u c c jay jay and again this is a statute this been brought up specifically for cases where the child's home state and the child are now somewhere else in our matter we had an actual jurisdictional conference pursuant to the u c c j a work of the nevada court and the champagne board actually led by congress for to discuss these matters to make that out after a period of six months and again what's different about this case is there is a normal basis here for jurisdiction illinois minor child i do want to touch to a couple of other matters affected a judgment on the basis subject matter jurisdiction is being forwarded time and i believe what court was trying to get to with the issue of bellville was that we don't want people to be coming back after the fact with the old reading  prostitution and making collateral tax based upon a regular us that's entirely different from what we're talking about here i don't think that bill stands for the problem with a promise that the constitution is going to trump jurisdiction in this matter which i think i was a completely conflicted cause of action is or is whether the whether the u c c jay jay would even apply here but a contrary reading of that would mean that a court could actually people could waive her rights at any time you regardless of where the child is regardless of where the subject matter jurisdiction lives and that would be a deviation from the way other states may or may not be interpreted whether the child may have minimal context in one state or the other or whether illinois sufficient context be under the whole state or whether there's an emergency basis for a jurisdiction there isn't any here under the circumstances under our reading of the statute and how it has been interpreted notwithstanding the constitutional arguments is illinois does not subject matter jurisdiction in this matter but here go to an issue here where there's four of nine venus but one issue go to a circumstance where ok now the jurisdiction was proper in illinois now it's proper in another state based upon that reading so you're saying  believe that is i believe it's very possible now the court never reached that issue because it found that the order of two thousand and ten was a boy but even that being the case i believe that your honor is correct that were the case to be remanded we would be in a situation we're in again right here where the court once again has to be dealing with the interests of the child or the child's living and worthless contacts lie and those contacts are in the state of nevada and happen in the state of nevada for the past fifteen or sixteen months just one final thing here mr wilson talked about the when the judgment was entered in two thousand and ten it's something to consider my client was pro se at the time she was nineteen years old she was not represented by an attorney that is a consideration here is that reserve the issue of child support and from two thousand and ten until two thousand and twelve i believe that mr roberts have i think that i honestly don't know but in looking at it and looking at my client's affidavit i believe that he appeared just a few hundred dollars or that if any of that leaves and again it's not something that changes visitation it's kept nothing to do with anything there's been no factual presentations to the court with respect to them so i think their red herrings i think i was astonished at their representation about yas something something to do with this case the familiar absolutely not it wasn't cited in the brief and i think there's a procedure you follow to a motion to supplement the brief that wasn't done i think it's inappropriate to even consider this