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    In the
    United States Court of Appeals
    For the Seventh Circuit
    
    No. 99-2262
    
    UNITED STATES OF AMERICA,
    
    Plaintiff-Appellee,
    
    v. 
    
    ROBERT HERBERT KRAMER,
    
    Defendant-Appellant.
    
    
    Appeal from the United States District Court
    for the Southern District of Indiana, Indianapolis Division.
    No. 98 CR 140--Sarah Evans Barker, Chief Judge.
    
    
    Argued November 12, 1999--Decided September 5, 2000
    
    
    
      Before FLAUM, Chief Judge, and RIPPLE and ROVNER,
    Circuit Judges.
    
      RIPPLE, Circuit Judge.  Robert Herbert Kramer was
    found guilty of the willful failure to pay a past
    due child support obligation in violation of the
    Child Support Recovery Act ("CSRA"), 18 U.S.C.
    sec. 228. On appeal, Mr. Kramer claims that he
    did not receive service of process in the state
    action seeking the child support order and that
    his federal conviction based on his noncompliance
    with that state order is therefore invalid. For
    the reasons set forth in the following opinion,
    we reverse Mr. Kramer's conviction and remand to
    the district court for further proceedings
    consistent with this opinion.
    
    I
    BACKGROUND
    A.
    
      Mr. Kramer, while a resident of Minnesota,
    worked as an over-the-road truck driver for
    Mayflower Van Lines, Inc. ("Mayflower"). In
    January 1980, when he first started working for
    Mayflower, he attended three weeks of training
    sessions in Indianapolis, Indiana. While in
    Indianapolis, he had a brief sexual relationship
    with Janice Jacobs, a resident of Indiana. By
    January 30, at the latest, Mr. Kramer left
    Indiana to return to Minnesota. On November 25,
    1980, Ms. Jacobs gave birth to a son, and she
    claims that Mr. Kramer is the father. When the
    child was born, Mr. Kramer received a call from
    his dispatcher, telling him that he was a father.
    
    
      In late 1982, Jacobs informed Mr. Kramer that
    she intended to file a paternity suit against
    him. She then filed a paternity action in the
    Marion County Circuit Court of Indiana. Mr.
    Kramer never appeared at any of the proceedings;
    Mr. Kramer submits that he never received either
    formal service of process or informal
    notification of the paternity proceedings. The
    state court file does not show that process was
    served, and neither party asserts that Mr. Kramer
    received service of process. In December 1982,
    the Indiana court established Mr. Kramer's
    paternity by default and directed him to pay $25
    per week in child support.
    
      Mr. Kramer insists that he first learned of the
    Indiana child support order in the fall of 1990.
    At that time, Mayflower informed him that an
    Indiana court had ordered it to withhold $50 from
    each two-week paycheck. This was required,
    Mayflower told Mr. Kramer, because of an
    outstanding child support order. Due to the
    attachment of his wages, Mr. Kramer hired an
    attorney to contest the default judgment
    establishing his paternity. Mr. Kramer failed to
    appear at his hearing dates, and his attorney
    eventually withdrew from representing him. After
    his attorney's withdrawal from representation,
    Mr. Kramer did not pursue this collateral attack
    on the default judgment. Then, in January 1992,
    Mr. Kramer stopped working for Mayflower. He left
    Mayflower because he had failed to renew his
    trucker's license and because he was suffering
    from both asthma and self-diagnosed depression.
    This depression, he claims, was caused in part by
    his worries over the outstanding child support
    order.
    
      Starting in June 1993, Mr. Kramer worked for
    Lenneman Transport. While at Lenneman Transport,
    none of his wages were attached due to the child
    support order. However, he injured his back while
    at work and left Lenneman Transport in February
    1994. Since that time, Mr. Kramer has not worked
    at all because he does not believe that he could
    pass a physical examination due to his bad back,
    his asthma, and his depression. 
    
      Mr. Kramer moved to the State of Washington in
    September 1996. Then, in July 1998, he was
    visited by an FBI agent about the outstanding
    child support order. Mr. Kramer informed the
    agent that, although he might be able to return
    to work, he did not see any reason to do so until
    the support order was cleared up because he would
    "just be attacked all the time." Tr.I at 41. A
    federal grand jury thereafter indicted Mr. Kramer
    on October 15, 1998, for the willful failure to
    pay, between October 1993 and December 1995, a
    past due support obligation with respect to a
    child residing in Indiana.
    
    B.
    
      The United States District Court for the
    Southern District of Indiana conducted a bench
    trial on the criminal charge against Mr. Kramer.
    At the close of the Government's case, Mr. Kramer
    moved for a judgment of acquittal, asserting that
    the Government had failed to prove that the
    underlying child support order was valid. He
    claimed that the order was invalid because he did
    not receive service of process and that the state
    court therefore did not have personal
    jurisdiction over him. The district court
    reserved its decision until the completion of the
    trial.
    
      At the end of the trial, the court found Mr.
    Kramer guilty of the willful failure to pay a
    past due support obligation in violation of 18
    U.S.C. sec. 228. The court first stated that the
    Government needed to prove beyond a reasonable
    doubt (1) that Mr. Kramer acted willfully, (2) in
    failing to pay, (3) a past due support
    obligation, (4) with respect to a child who
    resided in another state. The court found that,
    although "Kramer may not have learned of the
    lawsuit or the entry of the default judgment in
    1982, it is clear that he understood by at least
    1990 that such an order had been entered against
    him." R.20 at 7. Next, the court found that Mr.
    Kramer had failed to pay the $25 per week
    mandated by the court order during the period of
    the indictment. The court also found that, during
    the time stated in the indictment, the child
    covered by the support order resided in Indiana
    and Mr. Kramer resided in Minnesota. "Therefore,"
    the court concluded, "the evidence establishes
    beyond a reasonable doubt that Kramer knew prior
    to October 1993 that an Indiana state court had
    ordered him to pay child support for a child that
    resided in a different state than him and that he
    failed to do so." Id. at 8.
    
      The court next discussed the element of
    willfulness and stated: "We harbor no hesitancy
    in concluding that Kramer acted willfully in not
    paying the support amount due." Id. The court
    noted that Mr. Kramer had challenged the support
    order when it served his interest to do so. But
    then, when he left Mayflower and was no longer
    subject to the attachment of his wages, he no
    longer believed that he owed support. "Indeed,"
    the court stated, "we do not credit Kramer's
    assertion that he simply forgot that an
    outstanding support order existed, as other
    testimony he provided revealed that the
    outstanding matter caused him such discomfort as
    to contribute to his ongoing 'depression.'" Id.
    at 9.
    
      The court also addressed Mr. Kramer's argument
    that the underlying support order was invalid
    because the state court lacked personal
    jurisdiction over him. The court characterized
    Mr. Kramer's defense as a collateral attack on
    the state court default judgment. First, the
    court held that federal courts do not need to
    question the validity of support orders issued by
    state courts before entering a judgment of
    conviction under sec. 228. The court relied upon
    United States v. Bailey, 115 F.3d 1222, 1232 (5th
    Cir. 1997), for the proposition that the language
    of sec. 228 does not require a federal court to
    look beyond the four corners of the state child
    support order or permit a collateral attack on
    the state court order in federal court. Mr.
    Kramer, the court explained, should have
    challenged the state court default judgment
    through state channels, of which he was aware, as
    evidenced by his attempted collateral attack in
    1991. His failure to complete that process,
    continued the court, does not invalidate the
    support obligation element of sec. 228.
    
      Next, the court held that Mr. Kramer had been
    afforded sufficient due process in his federal
    prosecution. According to the court, Mr. Kramer
    had argued that, because he did not receive due
    process in the state default judgment, he was
    denied due process in the federal conviction
    because it relied on the state default judgment.
    According to the court, the Supreme Court in
    United States v. Mendoza-Lopez, 481 U.S. 828
    (1987), required the availability of meaningful
    review of a decision of an administrative
    proceeding as a necessary condition before a
    court imposed criminal sanctions based on that
    administrative decision. The court stated,
    however, that Mr. Kramer possessed an opportunity
    to seek review of the state default judgment
    before the imposition of his criminal sanction.
    Moreover, the court explained, "[a]ny putative
    due process violation occurring in 1982 was cured
    by the Indiana state court's granting Kramer a
    hearing to challenge that default judgment in
    late 1991." R.20 at 12.
    
      For these reasons, the court found Mr. Kramer
    guilty of the willful failure to pay a past due
    child support obligation for the period between
    October 1993 and December 1995. The court
    sentenced Mr. Kramer to one year of probation,
    with 60 days community confinement as a condition
    of his probation, and it ordered him to pay
    $19,750.00 in restitution.
    
    II
    DISCUSSION
    A.
    
      Mr. Kramer submits that he cannot be found
    guilty under the CSRA because the Government did
    not establish that the Indiana court that issued
    the support order had personal jurisdiction over
    him. He contends, as he did in the district
    court, that he was never served process nor
    notified of the state paternity proceeding which
    produced the support obligation. Without such
    notice and opportunity to be heard, he submits,
    the Indiana court did not have personal
    jurisdiction over him, see Mullane v. Central
    Hanover Bank, 339 U.S. 306, 313 (1950), and the
    default judgment issued by the Indiana state
    court does not constitute a valid "support
    obligation" under the CSRA.
    
      The Government has another view. It submits that
    it needed to prove beyond a reasonable doubt only
    the existence of the support order. Mr. Kramer's
    position, it contends, is an impermissible
    collateral attack on the state court child
    support order. Relying on our decision in United
    States v. Black, 125 F.3d 454 (7th Cir. 1997),
    the Government argues that a federal court cannot
    revise the domestic relationship decided by a
    state court. Therefore, the Government submits,
    Mr. Kramer's conviction should be upheld.
    
    B.
    1.
    
      We begin, as we must, with the wording of the
    statute. The CSRA punishes any person who
    "willfully fails to pay a support obligation with
    respect to a child who resides in another State,
    if such obligation has remained unpaid for a
    period longer than 1 year, or is greater than
    $5,000." 18 U.S.C. sec. 228(a). The term "support
    obligation" is defined as "any amount determined
    under a court order or an order of an
    administrative process pursuant to the law of a
    State . . . to be due from a person for the
    support and maintenance of a child or of a child
    and the parent with whom the child is living." 18
    U.S.C. sec. 228(f)(3). Nothing in this definition
    suggests that a defendant may defend a
    prosecution under this statute by contesting the
    substantive merits of the underlying support
    obligation. Indeed, courts interpreting the CSRA,
    including this one, have spoken with one voice on
    that issue. See United States v. Brand, 163 F.3d
    1268, 1275-76 (11th Cir. 1998); United States v.
    Black, 125 F.3d 454, 463 (7th Cir. 1997); United
    States v. Bailey, 115 F.3d 1222, 1232 (5th Cir.
    1997); United States v. Johnson, 114 F.3d 476,
    481 (4th Cir. 1997); United States v. Sage, 92
    F.3d 101, 107 (2d Cir. 1996).
    
      The question remains, however, whether a
    defendant in a federal CSRA prosecution may
    defend on the limited ground that the underlying
    state support obligation was imposed by a court
    that did not have personal jurisdiction over the
    defendant. The general rule for default judgments
    in civil actions is that the judgment may be
    attacked collaterally on the narrow ground that
    the judgment was void because the rendering court
    lacked the requisite nexus with the defaulting
    party or gave inadequate notice of the support
    action to that party. See Burnham v. Superior Ct.
    of Cal., 495 U.S. 604, 609-11 (1990); Kulko v.
    Superior Ct. of Cal., 436 U.S. 84, 91 (1978); see
    also World-Wide Volkswagen Corp. v. Woodson, 444
    U.S. 286, 291 (1980). To sustain the Government's
    position therefore, we must ascertain that
    Congress, in enacting the CSRA, intended to
    establish an approach different from the rule
    that usually applies.
    2.
    
      In an effort to demonstrate that Congress
    intended to permit a successful CSRA prosecution
    without a showing that the underlying support
    judgment had been issued by a court properly
    exercising personal jurisdiction over the
    defendant, the Government invites our attention
    to Custis v. United States, 511 U.S. 485 (1994),
    and Lewis v. United States, 445 U.S. 55 (1980).
    We shall examine each of these cases in
    chronological order.
    
      In Lewis, the defendant was charged with being
    a felon in possession of a firearm in violation
    of 18 U.S.C. sec. 1202(a)(1). See 445 U.S. at 57.
    In defending against the charge, he attempted to
    attack collaterally the prior state conviction
    that was the basis for prosecuting him as a felon
    in possession of a firearm. He claimed that this
    state conviction was invalid because he had not
    been represented by counsel, and, therefore, the
    conviction had been obtained in violation of his
    Sixth and Fourteenth Amendment rights. See id. at
    57-58. The Supreme Court rejected his argument.
    The Court stated that the statute forbidding a
    felon to possess a firearm did not permit a
    collateral attack on the underlying conviction on
    constitutional grounds. See id. at 65 (discussing
    18 U.S.C. sec. 1202(a)(1)). The Court explained
    that the plain language of the statute contained
    no exceptions to the definition of "prior
    conviction." Id. at 60. Moreover, continued the
    Court, Congress would have made such an exception
    explicit because, in other sections of the same
    statute, it had explicitly made exceptions to
    liability for those individuals who, despite a
    felony conviction, could be entrusted with a
    firearm under limited circumstances. See id. at
    61-62 (listing sections). Other statutes, the
    Court continued, explicitly permitted a defendant
    to challenge, by way of defense, the validity or
    constitutionality of the predicate felony. See
    id. at 62 (listing statutes). The Court further
    noted that the legislative history did not
    indicate any intent by Congress to permit a felon
    to contest the validity of the underlying
    conviction. See id. at 62-63. Indeed, the Court
    noted that the legislative history made clear
    that Congress intended a "sweeping prophylaxis"
    against the misuse of firearms. Id. at 63.
    Additionally, other sections forbade the
    reception of a firearm by someone indicted for a
    felony even if he was subsequently acquitted. See
    id. at 64. Finally, the Court noted that the
    convicted felon is not without relief; he could
    have had the underlying conviction removed by a
    qualifying pardon or could have challenged the
    prior conviction in the state court. See id. As
    the Court concluded, "Congress clearly intended
    that the defendant clear his status before
    obtaining a firearm." Id.
    
      The later Supreme Court case of Custis involved
    an interpretation of the Armed Career Criminal
    Act, 18 U.S.C. sec. 924(e), which provides for
    the enhancement of a sentence of a convicted
    firearms possessor who "has three previous
    convictions . . . for a violent felony or a
    serious drug offense." 511 U.S. at 487.
    Interpreting the statute before it, the Supreme
    Court held that there was no indication that
    Congress had intended to permit the defendant to
    challenge the predicate convictions on the ground
    that they were procured through errors of
    constitutional magnitude. See id. Notably, the
    Court grounded its analysis on the text and the
    structure of the particular statute before it,
    the Armed Career Criminal Act. See id. at 490-91.
    "The statute focuses on the fact of the
    conviction and nothing suggests that the prior
    final conviction may be subject to collateral
    attack for potential constitutional errors before
    it may be counted." Id. at 490-91. Moreover,
    noted the Court, the statute affirmatively
    provides that no conviction "which has been . . .
    set aside" may be counted and therefore "creates
    a clear negative implication that courts may
    count a conviction that has not been set aside."
    Id. at 491. The Court also noted that Congress
    had enacted other statutes that expressly permit
    repeat offenders to challenge convictions that
    are used for enhancement purposes. See id. at
    491-92.
    
      Although the Court in Custis held that a
    defendant could not attack collaterally the
    merits of the underlying conviction, the Court
    also held that a defendant could attack
    collaterally a state court conviction when the
    defendant had been convicted in violation of his
    right to counsel under the Sixth Amendment. The
    Court deemed such a violation akin to a
    "jurisdictional defect," see id. at 496, that
    raised questions about the court's power to
    render a decision at all and stated that "this
    Court [has] attributed a jurisdictional
    significance to the failure to appoint counsel,"
    id. at 494. 
    
    "If the accused, however, is not represented by
    counsel and has not competently and intelligently
    waived his constitutional right, the Sixth
    Amendment stands as a jurisdictional bar to a
    valid conviction and sentence depriving him of
    his life or his liberty. . . . The judgment of
    conviction pronounced by a court without
    jurisdiction is void, and one imprisoned
    thereunder may obtain release by habeas corpus."
    
    Id. (quoting Johnson v. Zerbst, 304 U.S. 458, 468
    (1938)). The Court concluded that the "failure to
    appoint counsel for an indigent defendant was a
    unique constitutional defect," and none of the
    other constitutional defects "rises to the level
    of a jurisdictional defect resulting from the
    failure to appoint counsel at all." Id. at 496. 
    
      Although these cases are somewhat helpful guides
    in deciding the case before us, their value is
    not the one that the Government ascribes to them.
    The analysis of the Supreme Court in Lewis and in
    Custis does not suggest that it is proper in
    every situation involving the use of an earlier
    procured judgment to refuse to allow an inquiry
    into the validity of that underlying judgment. To
    the contrary--and here we believe is the true
    value of Lewis and Custis to our present
    decision--these cases make clear that, in
    determining whether we should look into the
    validity of the underlying judgment, we must
    focus on the particular statutory scheme at issue
    and decide whether Congress expected courts to
    evaluate the validity of the underlying judgment.
    In Lewis and in Custis, the Court also made clear
    that we must focus on the language of the statute
    and the intent of Congress. See Custis, 511 U.S.
    at 490-92; Lewis, 445 U.S. at 60-61. In each
    case, the Court reached the issues that it did
    reach because of its interpretation of the
    congressional will in the particular statutory
    schemes. See Custis, 511 U.S. at 493; Lewis, 445
    U.S. at 64-65. Repeatedly in Lewis and in Custis,
    the Supreme Court contrasted the firearms
    statutes at issue with other sections of the
    criminal code that permitted the sort of
    collateral attack that the Court found
    impermissible under the statutes in those cases.
    It is also of great significance that, even when
    the Court in Custis determined that the statutory
    scheme did not permit the scrutiny of the merits
    of the underlying conviction, the Court did
    permit the examination of the jurisdictional
    basis of the underlying judgment. 
    
    3.
    
      As we already have noted, we have no quarrel
    with those courts that have held that Congress
    did not intend that a defendant could raise the
    correctness of the underlying support judgment as
    a defense. Indeed, as we previously have pointed
    out, this court is among those circuits that have
    so held. See Black, 125 F.3d at 454. In this
    case, however, our focus must be on whether
    Congress intended to prevent the defendant from
    raising as a defense to his CSRA prosecution that
    the state court rendered the support judgment
    without jurisdiction. To determine whether the
    general rule that allows a defendant to contest a
    default judgment on jurisdictional grounds has
    been abrogated by Congress in a prosecution under
    the CSRA, we must focus on that particular
    statute and the circumstances surrounding its
    passage. 
    
      The issue of the enforcement of support orders
    has been a focal point of legislative activity at
    both the national and state levels. Support
    obligations are part of the law of domestic
    relations and therefore are a significant
    responsibility of state government. Nevertheless,
    because so many of these obligations transcend
    state borders, interstate cooperation is vital,
    and, in recent years, the federal government has
    found it necessary to play a larger role in
    improving the overall national situation. As we
    noted in Black, "Congress has expressly
    recognized that collecting past due child support
    obligations from out-of-state deadbeat parents
    has outgrown state enforcement mechanisms." 125
    F.3d at 458.
    
      In 1988, Congress created the U.S. Commission on
    Interstate Child Support ("the Commission") and
    charged the Commission to "submit a report to
    Congress that contains recommendations for (A)
    improving the interstate establishment and
    enforcement of child support awards, and (B)
    revising the Uniform Reciprocal Enforcement of
    Support Act." Family Support Act of 1988, Pub. L.
    No. 100-485, sec. 126, 102 Stat. 2343, 2355
    (1988) (codified at 42 U.S.C. sec. 666).
    
      The Commission submitted its report to Congress
    in 1992. In its report, the Commission discussed
    the inefficiencies prevalent in the current
    system for the enforcement of interstate child
    support orders. See Supporting Our Children: A
    Blueprint for Reform, U.S. Commission on
    Interstate Child Support's Report to Congress xii
    (1992) [hereinafter Blueprint for Reform]. The
    Commission noted that almost $5 billion went
    uncollected in child support cases in 1989. See
    id. Moreover, the report explained, three out of
    every ten child support cases are interstate, yet
    only $1 of every $10 is collected in interstate
    cases. See id. Due to the poor rate of collection
    on interstate child support cases, the Commission
    sought to reform the old system of collection for
    a more effective one. See id.
    
      While the Commission was conducting its study,
    the prevailing statute governing interstate
    collection of past due support obligations was
    the Uniform Reciprocal Enforcement of Support Act
    ("URESA"), which contained both civil and
    criminal provisions. This model act was enacted
    throughout the United States, although in a
    variety of forms. Blueprint for Reform, at 16.
    The differences in URESA among the states
    contributed to delay and inefficiency. See id.
    Under URESA's civil provisions, a person seeking
    support for a child had two options for obtaining
    jurisdiction over a defendant. First, the
    plaintiff could transmit the appropriate legal
    documents to the defendant's state. The
    defendant's state would then take action to
    establish or enforce the support order against
    the defendant. Oftentimes, multiple orders would
    be issued. See id. at 228-31. Or, the plaintiff's
    state could exert its long-arm jurisdiction over
    the defendant. The reach of long-arm jurisdiction
    varied by state, increasing the difficulties in
    enforcing the support orders. Although URESA
    addressed the need for jurisdiction over the
    defendant and for service of process, the
    Commission report explained that the requirements
    for jurisdiction and notice varied by state and
    that oftentimes the requirements of one state
    would not be effective in a different state. See
    id. at 92-93.
    
      URESA also contained criminal provisions to
    facilitate the extradition of a defendant who had
    been charged with criminal nonsupport. See id. at
    17. The uniform act required the governor of a
    defendant's state to surrender the defendant,
    unless the defendant was complying with an
    existing support order, the defendant had
    prevailed on a previous support action, or the
    governor believed that civil remedies would be
    effective. See id. This process under URESA,
    however, remained a "tedious, cumbersome and slow
    method of collection." H.R. Rep. No. 102-771,
    1992 WL 187429 (1992).
    
      When the Commission wrote its report, it
    discussed extensively the importance of obtaining
    jurisdiction over the parties. See Blueprint for
    Reform, at 79-85. It explained that a court or
    agency can establish a child support obligation
    only if it has authority over the person. See id.
    at 79. It also discussed the obligation that
    states give full faith and credit to the support
    orders of sister states. It then recommended to
    Congress that it "provide for the interstate
    recognition and enforcement of child support
    orders, including ongoing orders, that are based
    on the valid exercises of jurisdiction up to
    constitutionally permissible limits." Id. at 91
    (emphasis added).
    
      The Commission also discussed a new uniform act
    for the states to follow. Rather than merely
    revising URESA, the Commission advocated the
    implementation of the radically different Uniform
    Interstate Family Support Act ("UIFSA"). See id.
    at 231. The basic premise behind UIFSA is that
    "there should be one support order between
    parties that is controlling at any given point in
    time." Id. at 232. Under this proposition, only
    one state controls the support obligation, and
    once that state obtains jurisdiction, it then has
    continuing, exclusive jurisdiction over the
    parties. See id. According to the Commission, to
    obtain jurisdiction over the parties, UIFSA
    contains a new provision for long-arm
    jurisdiction as well as retaining the two-state
    process introduced in URESA. See id. The
    Commission recommended that, "[s]ubject to the
    risk of losing federal funding, states shall
    adopt verbatim the [ ] drafting committee's final
    version of UIFSA." Id. at 236. By requiring the
    adoption of UIFSA verbatim, the Commission hoped
    to avoid the difficulties that had been attendant
    to the myriad versions of the old uniform act
    that the states had enacted. See id.
    
      Of particular importance to Mr. Kramer's case,
    the Commission also specifically discussed the
    role of service of process in interstate child
    support cases. The Commission noted that a
    support action begins with service of process to
    the defendant in order to perfect personal
    jurisdiction and to notify the defendant of the
    action. See id. at 92. It also explained that
    each affected party is entitled to receive notice
    and that a party who is not served properly with
    notice later may challenge jurisdiction. See id.
    Then, the Commission recommended that each state
    observe other states' service of process laws.
    See id. at 94. Also, the Commission wrote that
    "States shall have and use laws that provide
    that: . . . Notice required for the exercise of
    jurisdiction over an individual outside the forum
    state must be given in a manner reasonably
    calculated to give actual notice." Id. 
    
      The language of UIFSA itself also focuses on the
    importance of jurisdiction in child support
    cases. First, to establish a support order, the
    act states: "Upon finding, after notice and
    opportunity to be heard, that an obligor owes a
    duty of support, the tribunal shall issue a
    support order directed to the obligor . . . ."
    UIFSA sec. 401(c). If a support order has been
    issued already in another state, then the
    receiving state "shall recognize and enforce, but
    may not modify, a registered order if the issuing
    tribunal had jurisdiction." Id. sec. 603(c)
    (emphasis added). Also, the receiving tribunal
    shall notify the defendant of the registration of
    the support order issued by another state. See
    id. sec. 605(a). Although a defendant may not
    plead lack of parentage as a defense to a support
    obligation once another tribunal has established
    parentage, see id. sec. 315, the defendant may
    contest the validity or enforcement of the
    support order on the grounds that "the issuing
    tribunal lacked personal jurisdiction over the
    contesting party," id. sec. 607(a)(1).
    
      Congress acted on the recommendations of the
    Commission with a variety of legislative efforts.
    In the Full Faith and Credit for Child Support
    Orders Act, Pub. L. No. 103-383, sec. 3(a), 108
    Stat. 4063, 4064 (1994) (codified at 28 U.S.C.
    sec. 1738B), Congress provided that each state
    "shall enforce according to its terms a child
    support order made consistently with this section
    by a court of another State." Id. sec. 3(a)(1).
    It further provided that 
    
      A child support order is made consistently with
    this section if--
    
    (1) a court that makes the order, pursuant to the
    laws of the State in which the court is located--
    
    (A)  has subject matter jurisdiction to hear the
    matter and enter such an order; and 
    
    (B)  has personal jurisdiction over the
    contestants; and 
    
    (2) reasonable notice and opportunity to be heard
    is given to the contestants. 
    
    Id. sec. 3(c), 108 Stat. at 4065. Furthermore,
    Congress has mandated that each state enact UIFSA
    or lose federal funding.
    
      The Commission report also emphasized the
    importance of state criminal nonsupport statutes
    and recommended that all states enact them. See
    Blueprint for Reform, at 178. It stressed that
    felony penalties should be "reserved for the
    especially egregious cases of nonsupport" and
    that "criminal enforcement is a last resort
    enforcement device." Id. "Civil enforcement
    techniques should be tried before prosecuting [a
    defendant] for criminal nonsupport," the
    Commission warned. Id. The Commission recommended
    that there should be a federal criminal
    nonsupport statute to coexist with the state
    criminal nonsupport statutes. See id. The
    Commission explained that, although a state
    court's criminal jurisdiction over an out-of-
    state defendant is not clear cut, the federal
    government's jurisdiction is nationwide. See id.
    Then, the report states, "[t]he Commission
    encourages Congress to pass a statute that would
    make it a federal crime to willfully fail to pay
    support." Id. at 179. 
    
      The CSRA itself started through Congress before
    the Commission released its final report. The Act
    was developed, however, in consultation with the
    Commission and was based on a preliminary
    recommendation made by the Commission. See 138
    Cong. Rec. H7324-01, H7325 (daily ed. Aug. 4,
    1992) (statement of then-Rep. Schumer). The House
    Report revealed that, in August 1992, 42 states
    already had made willful failure to pay child
    support a crime, although the ability to enforce
    the criminal statutes diminished significantly
    once the nonpaying parent crossed state lines.
    See H.R. Rep. No. 102-771. Representative Hyde,
    who spearheaded the movement for the CSRA, stated
    that, although URESA was necessary, it was a poor
    substitute for a state's internal enforcement
    mechanism. See 138 Cong. Rec. H7324-01, H7326
    (statement of Rep. Hyde). He also stressed that
    the CSRA's goal was to strengthen, not supplant,
    state enforcement efforts. See id.
    
      During the House debates, one of the sponsors of
    the bill explained that:
    
      The bill would create a simple and
    straightforward criminal statute that would
    punish any person who willfully fails to pay a
    past-due support obligation to a child who
    resides in another State. 
    
      The bill also creates a grant program under
    which the Bureau of Justice Assistance may make
    grants to States and local entities to develop
    and implement this legislation and coordinate
    criminal interstate child support enforcement
    efforts.
    
      . . . Many of our States have done their best,
    and they have made willful failure to pay child
    support a crime punishable in some States by up
    to 10 years in prison. But the ability of those
    States to enforce such laws outside their own
    boundaries is hobbled by a labyrinth of
    extradition laws and snarls of red tape. As a
    result, skipping out on child support is one of
    the easiest crimes to get away with in America
    today.
    
    Id. at H7325 (statement of then-Rep. Schumer).
    Another representative, Representative Schiff,
    stated that "existing reciprocal support statutes
    between States are simply bogged down and unable
    to perform with the efficiency we would like to
    see." Id. at H7326 (statement of Rep. Schiff). No
    mention is made of jurisdiction or the validity
    of the underlying state support obligation in the
    legislative history of the CSRA.
    
    4.
    
      When we scrutinize the entire legal landscape
    surrounding the CSRA, it is clear that this
    criminal provision is only a small component in a
    nation-wide effort to deal with the need to
    enforce support orders. In addressing this
    problem, it is clear that, as Congress
    legislated, it was well aware of the long-
    standing rule, both in federal and state
    jurisprudence, that a default judgment in a civil
    case is void if there is no personal jurisdiction
    over the defendant and that a judgment may be
    attacked collaterally on that basis.
    Additionally, in addressing the problem of non-
    payment of support orders, the Commission
    emphasized the importance of jurisdiction and
    service of process in procuring support
    obligations. Although the problem of enforcement
    of child support orders has been the focus of
    both national and state legislative efforts for
    well over a decade, there is no indication that
    the Commission or Congress ever intended to
    abrogate the traditional rule that a default
    judgment procured without personal jurisdiction
    is a nullity. More precisely, the prevailing
    uniform act at the time of the CSRA's passage,
    URESA, allowed the defendant to attack
    collaterally the earlier state order on
    jurisdictional grounds. The new order of mutually
    supportive federal and state legislation
    continued the same adherence to traditional
    jurisdictional standards. Notably, the new
    uniform act, UIFSA, also allowed a defendant to
    attack collaterally the earlier state order on
    the limited ground that it was procured without
    jurisdiction. The related civil statutes that
    Congress enacted in the wake of the Commission's
    report accept the general rule that a defendant
    may attack collaterally the underlying support
    order because it was procured without
    jurisdiction over his person. See, e.g., 28
    U.S.C. sec. 1738B.
    
      Subjecting Mr. Kramer to criminal penalties for
    non-compliance with the state support judgment
    without allowing him to challenge the state
    court's personal jurisdiction would permit the
    federal criminal law to accomplish what the
    states forbid in their own civil and criminal
    courts and, indeed, what Congress has forbidden
    in the civil remedies it has created. In a
    carefully coordinated statutory scheme that
    places great emphasis on federal-state
    cooperation, such a result makes no sense.
    Because the CSRA itself, its legislative history,
    the Commission's report, the old and new uniform
    acts, and the federal statutes stemming from the
    Commission's report contain no indication that
    Congress intended to alter the traditional rule
    that a defendant may challenge on collateral
    attack a default judgment that is entered without
    personal jurisdiction, Mr. Kramer should be able
    to attack the Indiana child support order that
    formed the basis for his federal conviction for
    the willful failure to pay a past due support
    obligation. The failure of the district court to
    afford him the opportunity to do so constitutes
    reversible error. 
    
    C.
    
      There is another reason, firmly embedded in the
    statutory language, for permitting Mr. Kramer to
    argue that he ought not be criminally sanctioned
    without an opportunity to demonstrate that that
    judgment is a nullity because it was procured
    without jurisdiction. It is important to note
    that the statute proscribes only the willful
    disobedience of a state support order. Indeed,
    the legislative history of the statute makes
    clear that Congress intended that, in this
    statute, the term "willfully" be given the same
    meaning that it is given in the criminal tax
    statutes. See H.R. Rep. No. 102-771. Therefore,
    Congress, in enacting this statute, was well
    aware that, by using the term "willfully," the
    Government would be required to prove "an
    intentional violation of a known legal duty." Id.
    Indeed, quoting the Supreme Court's decision in
    United States v. Bishop, 412 U.S. 346, 361
    (1973), the House Report noted that the word
    "willfully" under the tax felony statute "imports
    a bad purpose or evil motive." See H.R. Rep. No.
    102-771.
    
      Under traditional principles, an individual can
    ignore a default judgment procured without
    jurisdiction and raise that lack of jurisdiction
    when the judgment creditor attempts enforcement.
    Mr. Kramer was denied the right to have his
    jurisdictional contention ever considered by the
    district court. Certainly, the maintenance of a
    meritorious jurisdictional defense would negate
    the element of willfulness./1
    
    Conclusion
    
      The district court erroneously held that Mr.
    Kramer's contention that the underlying judgment
    was procured without jurisdiction was not a
    defense to the charge. Accordingly, the judgment
    of the district court is reversed and the case is
    remanded for proceedings consistent with this
    opinion.
    
    REVERSED and REMANDED
    
    
    
    /1 Because Mr. Kramer contends that he has a
    meritorious defense on jurisdictional grounds
    that was never considered by the district court,
    it is premature, and indeed impossible on the
    record before us, to determine whether his
    position on the jurisdictional issue, even if
    erroneous, might have been held in good faith and
    therefore negated the element of willfulness
    necessary for criminal liability.
    

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