James Spies and Cynthia Carpenter separated after living with their children in Georgia. Carpenter returned to California with the children, obtained a temporary custody order there, and filed a California legal-separation action. Spies then filed for divorce and custody in Fulton County. After consulting the California court, the Georgia trial court dismissed the entire Georgia case as an inconvenient forum under the Uniform Child Custody Jurisdiction and Enforcement Act. The Supreme Court of Georgia held that the trial court could decline jurisdiction over the custody dispute because the children had lived and attended school in California for more than six months, California had already held hearings and issued a custody order, and the statutory factors supported California as the more efficient forum. But the trial court could not dismiss the divorce action under the UCCJEA. Although Georgia’s general forum-non-conveniens statute might potentially apply to noncustody matters, the trial court had not invoked it or made the findings needed for appellate review. The Court therefore affirmed in part and reversed in part, leaving the divorce case to proceed in Georgia and the custody matter subject to the California forum.