The Fourth Appellate District reversed a domestic violence restraining order and remanded. The court held that the trial court erred in failing to apply the Uniform Child Custody Jurisdiction Act in determining jurisdiction to include children, who were the subjects of child custody proceedings in Mexico, within the scope of a domestic violence restraining order.

The marriage of Maria Fernandez-Abin and Higinio Sanchez suffered an acrimonious breakdown. The two were married in Mexico in 1995. They had two children, a daughter born in 1998 and a son born in 2003. Both children were born in San Diego.