On April 11, 2026, Ayesha Howard filed a sworn affidavit in Los Angeles County Superior Court accusing Minnesota Timberwolves guard Anthony Edwards of concealing a California LLC, a Beverly Hills bank account, trademarks, and sports agency contracts to defeat a 2024 California child support ruling. The filing, reported by Yahoo Sports, seeks to reopen a March 2025 jurisdictional dismissal and matters because it tests how California courts treat hidden business contacts under Cal. Fam. Code § 4900 (UIFSA) and Cal. Code Civ. Proc. § 410.10.
Key Facts
| Detail | Information |
|---|---|
| What happened | Howard filed affidavit alleging Edwards concealed California business presence to evade jurisdiction |
| When | April 11, 2026 (filing); March 2025 (original dismissal) |
| Where | Los Angeles County Superior Court, California |
| Who's affected | Anthony Edwards, Ayesha Howard, their minor child |
| Key statutes | Cal. Fam. Code § 4900 (UIFSA); Cal. Code Civ. Proc. § 410.10 (long-arm statute) |
| Practical impact | Could revive California child support order against an out-of-state NBA player |
Why this matters legally
This filing forces California courts to decide whether undisclosed business contacts justify reopening a prior jurisdictional dismissal. Under California's long-arm statute, Cal. Code Civ. Proc. § 410.10, a court may exercise personal jurisdiction "on any basis not inconsistent with the Constitution." The constitutional test, set by International Shoe Co. v. Washington, 326 U.S. 310 (1945), requires "minimum contacts" with the forum state.
If Howard's allegations are accurate — a registered California LLC, a Beverly Hills checking account, California trademark filings, and an in-state agency contract — those continuous and systematic contacts can satisfy specific jurisdiction for any claim arising from those activities. Income flowing through a California LLC is directly relevant to a child support calculation, which means the contacts likely "arise from" or "relate to" the support claim under Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017).
The second issue is reopening a March 2025 ruling. Cal. Code Civ. Proc. § 473(b) allows relief from a judgment within six months for mistake, inadvertence, surprise, or excusable neglect. After six months, the only path is Cal. Code Civ. Proc. § 473(d) (void judgment) or extrinsic fraud — and intentional concealment of jurisdictional facts is the textbook example of extrinsic fraud under In re Marriage of Stevenot, 154 Cal. App. 3d 1051 (1984).
How California law handles this
California is one of the most aggressive states in the country at asserting jurisdiction over out-of-state child support obligors. Under the Uniform Interstate Family Support Act, codified at Cal. Fam. Code § 5700.201, California courts may exercise personal jurisdiction over a nonresident in eight enumerated circumstances, including when the individual "engaged in sexual intercourse in this state and the child may have been conceived by that act" or when "there is any other basis consistent with the constitutions of this state and the United States for the exercise of personal jurisdiction."
California child support is calculated under the statewide guideline at Cal. Fam. Code § 4055, which uses both parents' net disposable incomes and the percentage of time each parent spends with the child. For high-income obligors, courts routinely impute income from all sources, including LLC distributions, endorsement deals, and trademark licensing — exactly the categories Howard alleges Edwards concealed.
Disclosure obligations are non-negotiable. Cal. Fam. Code § 2104 requires a Preliminary Declaration of Disclosure, and Cal. Fam. Code § 2105 requires a Final Declaration of Disclosure listing all assets, liabilities, and income sources. Although those statutes apply directly to dissolution actions, California courts apply the same disclosure principles to support proceedings under Cal. Fam. Code § 3552, which requires production of tax returns and income documentation.
If a parent intentionally hides income or assets, Cal. Fam. Code § 1101(h) authorizes the court to award 100% of the undisclosed asset to the other party in dissolution cases, and analogous remedies exist in support enforcement. Courts may also impose sanctions under Cal. Fam. Code § 271 for conduct that frustrates settlement or increases litigation costs.
Practical takeaways
- Document every contact the obligor has with California — bank accounts, LLCs, real estate, agency contracts, endorsement deals, social media monetization tied to California vendors, and trademark filings with the U.S. Patent and Trademark Office showing California addresses.
- Subpoena financial institutions early. California's discovery rules, codified at Cal. Code Civ. Proc. § 2017.010, permit broad discovery of any matter relevant to the subject of the action.
- Consider filing under UIFSA in the obligor's home state if California jurisdiction fails. Cal. Fam. Code § 5700.301 allows direct registration of a support order in another state for enforcement.
- Preserve the extrinsic fraud claim by acting promptly. Although extrinsic fraud has no fixed limitations period, courts apply laches — unreasonable delay in seeking relief can defeat the claim.
- Request a vocational and financial forensic evaluation. California allows appointment of experts under Cal. Evid. Code § 730 to trace concealed income through complex business structures.
- Hire counsel licensed in California, not just the obligor's home state. Jurisdictional challenges and reopening motions involve California-specific procedural rules that out-of-state counsel often miss.
Frequently Asked Questions
FAQs
Can California exercise jurisdiction over an out-of-state NBA player?
Yes, California can exercise personal jurisdiction over an out-of-state professional athlete if the player has minimum contacts with the state. Under Cal. Code Civ. Proc. § 410.10, continuous business activities such as a California LLC, in-state bank accounts, or endorsement contracts performed in California can satisfy the constitutional test for specific jurisdiction in a child support case.
How long do I have to reopen a California family court order based on hidden assets?
You generally have six months under Cal. Code Civ. Proc. § 473(b) for mistake or excusable neglect, but extrinsic fraud claims have no fixed deadline. Concealment of jurisdictional facts qualifies as extrinsic fraud under In re Marriage of Stevenot, 154 Cal. App. 3d 1051 (1984), allowing reopening years later if you act without unreasonable delay.
What income counts when calculating California child support for a high earner?
California child support uses net disposable income from all sources under Cal. Fam. Code § 4058, including salary, bonuses, LLC distributions, endorsement deals, royalties, trademark licensing, and investment income. The statewide guideline at Cal. Fam. Code § 4055 applies to all income, with no statutory cap, although high-income obligors may rebut the guideline as excessive.
What happens if a parent is caught hiding income or assets in a California support case?
California courts may impute the concealed income, award sanctions under Cal. Fam. Code § 271, and in dissolution cases award 100% of the undisclosed asset to the other party under Cal. Fam. Code § 1101(h). Courts may also order payment of the other party's attorney fees and refer the matter for criminal perjury prosecution.
Does an LLC formed in California create personal jurisdiction over its owner?
It can. A California LLC creates continuous and systematic contacts with the state, and income flowing through that LLC is directly relevant to a child support claim. Under Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017), courts apply a "relate to" test — and LLC distributions counted as parental income clearly satisfy that standard.
Need California Family Law Help?
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This article discusses recent news and provides general legal commentary. It does not constitute legal advice. Every case is unique. Consult a qualified family law attorney for advice specific to your situation.