In this era of globalization, many families maintain multiple residences in different countries and bear different nationalities. Consequently, family members may be subject to concurrent jurisdiction of multiple countries. New York courts, through various statutes, are given broad jurisdictional power to entertain matrimonial and family law actions involving international families. At the same time, pursuant to the doctrine of forum non conveniens, codified in CPLR 327(a), a New York court may decline jurisdiction and dismiss an action where the action would be better adjudicated elsewhere.1

Increased use of the doctrine of forum non conveniens in recent matrimonial actions reflects a growing trend among New York courts of reluctance to hear cases brought by non-U.S. residents.2 New York courts have emphasized that “it is the convenience of the court, not that of either litigant, that controls” a forum non conveniens determination.3 In some cases, foreign matrimonial litigants’ choice of New York courts was characterized as “forum shopping.”4