Supreme Court of Missouri
J.c.w. and T.d.w., Minors, by Their Next Friend, Kelly K. Webb, Appellant v. Jason L. Wyciskalla, Respondent
January 27, 20092009 Mo. LEXIS 11
Summary
The court held that the circuit court possessed both subject matter and personal jurisdiction and that Missouri recognizes no separate category of jurisdictional competence. It treated the arrearage-bond requirement as a statutory limit on relief, not a jurisdictional bar, but required a judicial determination of arrearages and reasonable attorney fees before the statute could prevent a modification filing. Because the record did not establish the amount of arrearages, the constitutional challenge was unripe, requiring vacatur and remand for a new hearing.