Chelsey Bowman filed a Georgia custody petition while visiting family in the state, even though the children and their father had lived in Michigan and Wisconsin for much of their lives. The Georgia trial court concluded that it had jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act. Luke Bowman sought interlocutory review. The Georgia Court of Appeals held that Georgia was not the children’s home state and that the record did not establish the significant connections and substantial evidence required for Georgia to exercise initial custody jurisdiction. The court rejected the trial court’s reliance on the mother’s Georgia family ties and temporary parenting time because physical presence alone was insufficient. It reversed the jurisdictional order and remanded with direction to dismiss the petition for lack of subject-matter jurisdiction. A separate opinion would have affirmed, reasoning that the mother had moved to Georgia, maintained a meaningful relationship with the children, and exercised parenting time there.