Tennessee judge finds domicile in Tennessee, holds hearing on jurisdiction in Nossinger divorce

A Dixon County chancellor on Thursday heard competing jurisdictional claims in the divorce between Carrie Nossinger and Reed Allen Nossinger and allowed the husband to testify remotely before ruling that Tennessee is the appropriate forum to decide the case.

The ruling was limited to the jurisdictional question: whether the Tennessee chancery court or a divorce action filed by Reed Nossinger in Los Angeles County, California, should proceed first. The court then deferred the parties' substantive motions about spousal support, division of marital debt, exclusive possession of the marital residence and sale of a vacation property until after the California court's May hearing.

The issue arose after Reed Nossinger filed for divorce in Los Angeles in November 2024 and Carrie Nossinger filed in Dixon County in December 2024. Counsel for the parties disputed whether Reed had satisfied California's six-month residency requirement when he filed there; Tennessee law requires a six-month residency in this state to establish venue for divorce. The defendant testified remotely that he moved to Los Angeles in February 2023 and maintained a lease at 8218 West Sunset Boulevard.

Judge David D. Wolfe said he would hear evidence on the jurisdictional issue and, after testimony from both parties and argument by counsel, announced on the record that the evidence supported Tennessee jurisdiction. In explaining the ruling the judge cited statutory residency rules and credibility findings. The court noted that the parties continued to own multiple parcels in Tennessee, that vehicle registrations and insurance remained tied to Tennessee addresses, and that federal tax filings for 2022 and 2023 showed Tennessee residency. The judge told counsel he would issue a written order outlining the factual basis for the decision.

Before making that finding the court considered procedural arguments from both sides about the so-called "prior pending suit" doctrine and the Full Faith and Credit principles. Defense counsel urged deference to the California action as the first filing; plaintiff's counsel argued Tennessee was the more appropriate forum because the parties' real property and many indicia of domicile remained here. The court cited precedent that a first filing in another forum does not automatically bar Tennessee from hearing a case and confirmed the determination turns on the factual question of domicile and related contacts.

Judge Wolfe also resolved several procedural matters during the hearing: he granted a request to permit Reed Nossinger to testify via audio-visual transmission under Tennessee Rule of Civil Procedure 43.01, ruling that "exceptional circumstances" and judicial economy warranted remote testimony for the jurisdictional inquiry. The court accepted that defense counsel Justin Walker had ultimately filed an acceptance of service, which rendered the plaintiff's separate motion to declare service moot.

As to next steps, the judge said the parties' pending motions on temporary relief would be continued so the California court can hold its jurisdictional hearing, scheduled in Los Angeles in late May. The chancery court set a status conference for 1:30 p.m. on May 30 to learn the California court's decision and to determine whether to proceed on the remaining motions.

The judge cautioned counsel that if both courts exercise jurisdiction the parties risk duplicative litigation and appeals, and he said his written findings will be provided to the California court.

No final rulings were made on spousal support, property division or sale requests; those matters remain pending and were continued for further scheduling after the May jurisdictional hearing in California.

Courtroom testimony and argument for the jurisdictional hearing are part of the record in Dixon County Chancery Court.