The New Jersey Appellate Division ruled that the lower court did not possess personal jurisdiction over a nonresident alleged to have fathered a child during a sexual relationship with a New Jersey resident when the child was conceived in New York. The Court analyzed the issue under New Jersey’s Uniform Interstate Family Support Act. More specifically, the Court turned to N.J.S.A. 2A:4-30.129(a), which declared that New Jersey courts may exercise personal jurisdiction in an action to determine the parentage of a child over a nonresident individual in any one of seven instances. The Appellate Division ruled that the lower court did not have jurisdiction because the mother presented insufficient evidence to establish any of the seven instances.