The Uniform Interstate Family Support Act (UIFSA), for all of its broad reach, does not seek to give child support jurisdiction where there is no in personam jurisdiction over the payor, but the new Federal Child Support Recovery Act, 18 USC § 228 (1992), is something else again -- at least according to the U.S. Court of Appeals for the Fourth Circuit. In U.S. v. Murphy, ___ F 3d ___, 12 VLW 162 (6/26/97), a case in which the divorce was in Oklahoma and the father had never lived in Virginia, nor been ordered here to make any child support payments at all, a majority holds that he can be criminally prosecuted in the Western District because the mother and child have moved here. The majority explains that the father committed his crime of failure to pay support in Virginia because that is were the child to whom he owes the payments resides. This, will be remembered, was the theory of the California child support authorities which the U.S Supreme Court rejected in Kulko v. California Superior Court, 436 U.S. 84, 93 (1978) when it said in a civil context that a Father had created California in personam jurisdiction without ever coming to the state because he failed to stop his divorced wife and child from coming there. Concurring, Judge Williams says that the conviction should stand because venue is proper in the Western District of Virginia. He points out, however, that the CSRA does not purport to create venue wherever the child resides (yet its “designation for disbursement” creates proper venue here), and that a legislative purpose is not enough to overcome a constitutional requirement that venue should be where the crime was committed.