In Oytan v. David-Oytan, Division 1 of the Washington State Court of Appeals considered whether, in a dissolution proceeding, the husband who had never resided in Washington State could be subject to Washington courts for the purposes of dividing assets, entering child support, and ordering attorney fees. The Court of Appeals held that there was personal jurisdiction over the husband under Washington’s long-arm statute, RCW 4.28.185(1)(f), providing for jurisdiction over persons “living in a marital relationship
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