The case of Kulko v. Superior Court1 has a place in both family law and civil procedure jurisprudence. In Kulko, the Supreme Court declined to find that California had personal jurisdiction over a father after his children relocated to live with their mother in California and the mother sued to modify custody and support in a state court. In the family law context, it underscored the need for uniform legislation to address child support orders and modifications. In the civil procedure context, it recognized distinctions between cases in the public commercial sphere and in the private family sphere for the purpose of establishing personal jurisdiction, but reiterated the applicability of the minimum contacts test as the measure of due process under the Fourteenth Amendment in all spheres. While the California courts that heard the motion to quash service presented by petitioner, Ezra Kulko, all determined that the long-arm statute of California appropriately reached him, the U.S. Supreme Court disagreed.