[Cite as Pula v. Pula-Branch, 129 Ohio St.3d 196, 2011-Ohio-2896.] 

PULA ET AL., APPELLANTS, v. PULA-BRANCH, APPELLEE. 

[Cite as Pula v. Pula-Branch, 129 Ohio St.3d 196, 2011-Ohio-2896.] 

Uniform Interstate Family Support Act — R.C. Chapter 3115 — Domestic 

relations courts are authorized to decide cases brought under UIFSA — 

Judgment reversed, and cause remanded. 

(No. 2010-0985 — Submitted April 6, 2011 — Decided June 22, 2011.) 

APPEAL from the Court of Appeals for Cuyahoga County, No. 93460, 

2010-Ohio-912. 

__________________ 

 PFEIFER, J. 

{¶ 1} This case concerns which courts have jurisdiction to address 

interstate petitions of child support brought under the Uniform Interstate Family 

Support Act (“UIFSA”), R.C. Chapter 3115. The specific issue is whether the 

domestic relations division of the Cuyahoga County Common Pleas Court has 

subject-matter jurisdiction over an interstate support order when the order is 

unrelated to a divorce, dissolution of marriage, legal separation, or annulment. 

We hold that the Cuyahoga County Domestic Relations Court does have subjectmatter jurisdiction in this case. 

Factual and Procedural Background 

{¶ 2} Appellant Ruby K. Pula is a resident of Hawaii and the custodian 

and maternal grandmother of K.G.P., a minor child born out of wedlock. K.G.P. 

resides with Pula; appellee, Adrienne Haunani Pula-Branch, K.G.P.’s birth 

mother, lives in Cleveland. On November 18, 2008, on Pula’s behalf, appellant 

Cuyahoga Support Enforcement Agency (“CSEA”) filed in the domestic relations 

court a petition for child support and medical coverage against Pula-Branch. 
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{¶ 3} On May 15, 2009, the trial court issued a child-support order, but 

CSEA timely appealed to the Eighth District Court of Appeals, challenging the 

trial court’s calculation of child-support obligations. On January 20, 2010, the 

appellate court sua sponte raised the issue of the domestic court’s jurisdiction over 

the underlying action and ordered briefing. The court ultimately concluded that 

the domestic relations court lacked subject-matter jurisdiction over the petition. 

The court held that the Cuyahoga County Domestic Relations Court’s jurisdiction 

was limited by R.C. 2301.03(L)(1) to matters involving “a divorce, dissolution of 

marriage, legal separation, or annulment” and reasoned that since this case 

involved none of the actions set forth in R.C. 2301.01(L)(1), the Cuyahoga 

County Domestic Relations Court had no jurisdiction to address a UIFSA support 

order. Pula v. Pula-Branch, Cuyahoga App. No. 93460, 2010-Ohio-912, ¶ 8. 

The court noted that the case would be properly brought in juvenile court pursuant 

to R.C. 2151.23(B)(3), which states that the juvenile court has original 

jurisdiction under the UIFSA. Id. at ¶ 14, fn. 4. The appellate court ordered the 

Cuyahoga County Domestic Relations Court to vacate its order for lack of 

subject-matter jurisdiction. Pula at ¶ 14. 

{¶ 4} CSEA appealed. The cause is before this court upon the 

acceptance of a discretionary appeal. Pula v. Pula-Branch 126 Ohio St.3d 1581, 

2010-Ohio-4542, 934 N.E.2d 354. 

Law and Analysis 

{¶ 5} The UIFSA is codified in Ohio in R.C. Chapter 3115. Pursuant to 

R.C. 3115.16(B)(1), a “responding tribunal” that receives a complaint from an 

initiating state may issue or enforce a support order “to the extent otherwise 

authorized by law.” R.C. 3115.01(R) defines “[r]esponding tribunal” as “the 

authorized tribunal in a responding state”; the definition of “[t]ribunal” in R.C. 

3115.01(X) includes “any trial court of record of this state.” There is no dispute 

that the domestic relations court is a tribunal under the statute. The central issue 
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of this case is whether that court is “authorized”; the appellate court held that the 

Cuyahoga County Domestic Relations Court is authorized to hear and decide only 

cases that relate to a divorce, dissolution, legal separation, or annulment of a 

marriage. Pula, 2010-Ohio-912, ¶ 14. We disagree with the determination that 

the court’s jurisdiction is so limited and therefore reverse the judgment of court of 

appeals. 

{¶ 6} The General Assembly defines the jurisdiction of the courts of 

common pleas and their respective divisions. Sections 4(A) and (B), Article IV, 

Ohio Constitution. R.C. 2301.03 establishes the jurisdiction of the state's 

domestic relations courts in separate subsections; their jurisdiction can vary by 

county. R.C. 2301.03(L)(1) applies specifically to the judges of Cuyahoga 

County Domestic Relations Court. That statute sets forth that the judges of that 

domestic relations court “shall * * * exercise the same powers and jurisdiction * * 

* as other judges of the court of common pleas of Cuyahoga county and shall be 

elected and designated as judges of the court of common pleas, division of 

domestic relations. They shall have all the powers relating to all divorce, 

dissolution of marriage, legal separation, and annulment cases, except in cases 

that are assigned to some other judge of the court of common pleas for some 

special reason.” R.C. 2301.03(L)(1) grants all the power in marriage-related 

cases to the domestic relations division, thus limiting the ability of other common 

pleas judges to preside over those cases. Conversely, there is no limiting 

language preventing domestic relations judges from having jurisdiction over other 

cases – they retain “the same powers and jurisdiction * * * as other judges of the 

court of common pleas.” Thus, R.C. 2301.03(L)(1) is not a limiting provision, 

but rather a specific grant of authority. 

{¶ 7} The appellate court held that Pula’s petition should have been filed 

in juvenile court. Pula, 2010-Ohio-912, ¶ 14, fn. 4. R.C. 2151.23(B), which deals 

with the original jurisdiction of juvenile courts, states that juvenile courts have 
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original jurisdiction “[u]nder the uniform interstate family support act in Chapter 

3115. of the Revised Code.” R.C. 2151.23(B)(3). But that jurisdiction is not 

exclusive. R.C. 2151.23(A) sets forth the exclusive original jurisdiction of 

juvenile courts, and UIFSA cases are not listed among the matters over which 

juvenile courts have exclusive jurisdiction. This court has held that the distinction 

between exclusive original jurisdiction and nonexclusive original jurisdiction is 

crucial. In Brookbank v. Gray (1996), 74 Ohio St.3d 279, 658 N.E.2d 724, 

paragraph three of the syllabus, this court held that the issue of an illegitimate 

child's paternity may be litigated in a wrongful-death case in the court of common 

pleas. We held that although the “juvenile court has been given ‘original 

jurisdiction’ to determine the paternity of children born out of wedlock[,] * * 

*[t]his is in contrast to the ‘exclusive original jurisdiction’ given to the juvenile 

court over other matters.” Brookbank at 293, quoting R.C. 2151.23(A) and (B)(3). 

{¶ 8} Indeed, cases brought pursuant to R.C. Chapter 3115 are explicitly 

excluded from the juvenile court’s exclusive jurisdiction. R.C. 2151.23(A)(11) 

grants exclusive jurisdiction to juvenile courts to “hear and determine a request 

for an order for the support of any child if the request is not ancillary to an action 

for divorce, dissolution of marriage, annulment, or legal separation, * * * or an 

action for support brought under Chapter 3115. of the Revised Code.” (Emphasis 

added.) Thus, if the sought-after support order arises in a domestic relations case 

or an R.C. Chapter 3115 case, the juvenile court does not have exclusive 

jurisdiction over support orders. Since juvenile courts do not have exclusive 

jurisdiction under R.C. Chapter 3115 claims, other courts may hear those cases. 

{¶ 9} The UIFSA is remedial legislation and as such, pursuant to R.C. 

1.11, must be “liberally construed in order to promote [its] object and assist the 

parties in obtaining justice.” The facilitation of interstate support orders would 

not be promoted by foreclosing the Cuyahoga County Domestic Relations Court 

from considering UIFSA cases that do not arise from a marriage. The Cuyahoga 
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County Domestic Relations Court is a trial court of record in Ohio, one attuned to 

crafting support orders. The jurisdiction of the domestic relations division of the 

Cuyahoga County Common Pleas Court is not limited by statute to cases 

involving marriage, divorce, separation, or annulment; those judges “exercise the 

same powers and jurisdiction * * * as other judges of the court of common pleas 

of Cuyahoga county.” R.C. 2301.03(L)(1). Finally, jurisdiction over an action for 

support brought under R.C. Chapter 3115 is not exclusive to juvenile courts. R.C. 

2151.23(A)(11). 

{¶ 10} Therefore, we hold that the Cuyahoga County Domestic Relations 

Court does have jurisdiction over an action for support brought pursuant to R.C. 

Chapter 3115, even if the action does not arise from a divorce, dissolution of 

marriage, legal separation, or annulment. Accordingly, we reverse the judgment 

of the court of appeals and remand the case to the appellate court for further 

determination consistent with this opinion. 

Judgment reversed 

and cause remanded. 

 O’CONNOR, C.J., and LUNDBERG STRATTON, O’DONNELL, LANZINGER, 

CUPP, and MCGEE BROWN, JJ., concur. 

__________________ 

William D. Mason, Cuyahoga County Prosecuting Attorney, and Kestra 

Smith and Joseph Young, Assistant Prosecuting Attorneys, for appellant 

Cuyahoga Support Enforcement Agency. 

Michael DeWine, Ohio Attorney General, Alexandra Schimmer, Solicitor 

General, Emily S. Schlesinger, Deputy Solicitor, and Alana R. Shockey, Assistant 

Attorney General, urging reversal for amicus curiae Ohio Attorney General. 

______________________