KRISTINA EILEEN CODINO v. CHRISTOPHER JOHN CODINO - Articles

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KRISTINA EILEEN CODINO v. CHRISTOPHER JOHN CODINO

Posted by: Azya Thornton on Jul 22, 2026

Court: TN Court of Appeals

Attorneys 1: Heather C. Grewe, Pinson, Tennessee, for the appellant, Kristina Eileen Codino.

Attorneys 2: Alexander D. Camp, Jackson, Tennessee, for the appellee, Christopher John Codino.

Judge(s): MCGEE

The parties to this appeal were divorced in Virginia, and the divorce decree provided that they would alternate parenting time with their young child every three weeks. The mother moved to Tennessee, and the father later moved to Minnesota. After residing in Tennessee for ten months, the mother filed a petition in Tennessee seeking to have the Tennessee court enforce the Virginia divorce decree with respect to her allegations of contempt and modify the Virginia decree to name her primary residential parent. The father subsequently sought to register the Virginia decree in Minnesota. After a hearing, the Tennessee court found that Virginia had lost exclusive continuing jurisdiction because all parties had left that state and that Tennessee now had jurisdiction to modify the divorce decree because it qualified as the child’s home state. However, the Tennessee court declined to exercise its jurisdiction upon finding that Minnesota would be a more convenient forum for the litigation, primarily based on the fact that the Virginia divorce decree contained an agreement of the parties stating that the child would be enrolled in school in Minnesota upon reaching school age if the father was still residing there. The trial court dismissed the petition and awarded the father a portion of his attorney fees. The mother appeals, arguing, among other things, that the trial court erred in its analysis of the statutory factors under the inconvenient forum statute, erred by dismissing her request for enforcement of the Virginia decree, and erred by granting the father his attorney fees. We agree and reverse the trial court’s order of dismissal and its award of attorney fees. This matter is remanded for further proceedings consistent with this opinion

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