Commander Toland, Left Behind Parent, scores a non-custodial victory in Washington State. Posted on September 27, 2012 by hoofin 2 PDF of the opinion, here: Estate of Toland v. Toland. And here. I will hopefully do a review sometime later, but the bottom line is that Washington State said it wasn’t bound by the divorce decree and support order that was issued in Japan. One reason is that Paul did not receive due process.