The South Florida Sun-Sentinel reports that Michael Newdow originally filed his lawsuit in Broward county, where he was living with his parents. The judge dismissed the case without a hearing when she discovered that Newdow had moved to California.
There's also a little bleat from his mother, who winters in Florida:
"He’s not against the Pledge of Allegiance," his mother said, fearing that her son will be labeled unpatriotic. "He’s just against that part of it."