International Parental Child Abductions
Alison M. Smith
Legislative Attorney
December 3, 2012
Congressional Research Service
7-5700
www.crs.gov
RS21261
CRS Report for Congress
Pr
epared for Members and Committees of Congress
International Parental Child Abductions
Summary
International child custody disputes are likely to increase in frequency as the global society
becomes more integrated and mobile. A child custody dispute between two parents can become a
diplomatic imbroglio between two countries. Since 1988, the Hague Convention on the Civil
Aspects of International Child Abduction (“Hague Convention” or “Convention”) has been the
principal mechanism for enforcing the return of abducted children to the United States. While the
treaty authorizes the prompt return of the abducted child, it does not impose criminal sanctions on
the abducting parent. Congress, to reinforce the Hague Convention, adopted the International
Parental Kidnapping Crime Act of 1993 to impose criminal punishment on parents who
wrongfully remove or retain a child outside U.S. borders.
The Convention does not act as an extradition treaty, nor does it purport to adjudicate the merits
of a custody dispute. It is a civil remedy designed to preserve the status quo by returning an
abducted child to the country of his or her “habitual residence” and allowing the judicial
authorities in that country to adjudicate the merits of a custody dispute. As such, the proceeding is
brought in the country to which the child was abducted or in which the child is retained. Although
domestic relations involve issues typically governed by state law, the federal statute
implementing the Hague Convention explicitly confers jurisdiction on the federal courts. Federal
courts are split as to the scope of this jurisdiction. Both the Convention and its implementing
legislation are silent on the issue of appellate review. In Chafin v. Chafin, the U.S. Supreme Court
will weigh in on this issue when it decides whether an appeal of a district court’s decision
granting a return petition becomes moot after the child at issue returns to her country of habitual
residence, as determined by the district court.
The Hague Convention is not always applicable in international child custody cases. Signatory
nations do not have to automatically return a child to his or her place of habitual residence, as
discretionary exceptions exist that enable the child to remain with the removing parent. Also,
procedures and remedies available under the Convention differ depending on the parental rights
infringed. Courts must determine whether a particular order confers a right of custody or a lesser
right of access. For example, federal courts disagreed on what type of right was conferred by a ne
exeat, or “no exit,” order granting one parent the right to veto another parent’s decision to remove
their child from his home country. In Abbott v. Abbott, the U.S. Supreme Court resolved the
circuit split by finding that such an order confers a right of custody, thus triggering enforceability
under the Convention. However, it is important to note that this decision was limited to ne exeat
orders. As such, courts will have to address which side of the access-custody line any other
arrangements may fall.
This report will discuss the applicability of the Hague Convention and current U.S. laws, both
civil and criminal, which seek to address the quandary of children abducted by parents to foreign
nations. This report will be updated as events warrant.
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International Parental Child Abductions
Contents
Introduction ...................................................................................................................................... 1
Hague Convention ........................................................................................................................... 1
Rights of Custody vs. Rights of Access ..................................................................................... 2
Exceptions to a Child’s Prompt Return ..................................................................................... 4
Current U.S. Laws ........................................................................................................................... 5
International Child Abduction Remedies Act (ICARA) ............................................................ 5
International Parental Kidnapping Crime Act (IPKCA) ............................................................ 6
Fugitive Felon Act ..................................................................................................................... 7
Extradition Treaties Interpretation Act of 1988 ......................................................................... 7
Admiral James W. Nance and Meg Donovan Foreign Relations Authorization Act,
Fiscal Years 2000 and 2001 .................................................................................................... 7
Immigration and Nationality Act (INA), as Amended ............................................................... 7
Contacts
Author Contact Information............................................................................................................. 8
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Introduction
International child abduction is not new. However, one can argue that incidents of child abduction
continue to increase due to the ease of international travel as well as an increase in bicultural
marriages. Parental child abduction across international boundaries often garners global attention
and demands for international solutions. Since 1988, the Hague Convention on the Civil Aspects
of International Child Abduction (“Hague Convention” or “Convention”) has been the principal
mechanism for enforcing the return of abducted children to the United States.1 While the
Convention promotes the prompt return of an abducted child,2 it does not impose criminal
sanctions on the abducting parent. Moreover, the Convention’s available remedies do not apply to
nations that fail to participate. The Convention’s procedures are inapplicable and unenforceable in
nonsignatory nations.3 As such, parents and governments must often embark on the difficult and
sometimes impossible task of seeking other means of resolving international child custody
disputes with such nations.4
Hague Convention
The Hague Convention protects children from wrongful removal across international borders and
provides procedures to aid in their safe return.5 The Convention’s platform is intended to
guarantee that one signatory nation will respect and follow the custody rights and laws of all other
signatory nations.6 The signatory nations are Argentina, Australia, Austria, the Bahamas,
Belgium, Belize, Bermuda, Bosnia-Herzegovina, Brazil, Bulgaria, Burkina Faso, Canada, the
Cayman Islands, Chile, Colombia, Costa Rica, Croatia, Czech Republic, Cyprus, Denmark,
Dominican Republic, Ecuador, El Salvador, Estonia, the Falkland Islands, Finland, France,
Germany, Greece, Guatemala, Honduras, the Hong Kong Special Administrative Region,
Hungary, Iceland, Ireland, the Isle of Man, Israel, Italy, Latvia, Lithuania, Luxembourg, Macau,
1 Throughout this memorandum, “abduction” and “kidnapping” refer to the unlawful removal or retention of a child by
one parent to deprive the other parent of the rights of custody and access to that child. See International Parental
Kidnapping Crime Act of 1993, codified at 18 U.S.C. §1204.
2 See Hague Conference on Private International Law: Final Act, Draft Conventions on Civil Aspects of International
Child Abduction and on International Access to Justice, Articles on the Law Applicable to Certain Consumer Sales,
and Recommendations and Decisions of the Conference, October 25, 1980, 19 I.L.M. 1501 (1980) (hereinafter Hague
Convention).
3 If a child is abducted from the United States to a country that is not a party to the Hague Convention, the parent can
petition a court in that country to enforce a U.S. custody order. However, U.S. laws are not binding or legally
enforceable in a nonsignatory country unless the country does so voluntarily as a matter of comity.
4 See Cara L. Finan, Comment, Conventions on the Rights of the Child: A Potentially Effective Remedy in Cases of
International Child Abduction, 34 Santa Clara L. Rev. 1007, 1008 (1994) (noting that the U.S. State Department cannot
help parents when dealing with non-Hague nations); see also Lara Cardin, Comment, The Hague Convention on the
Civil Aspects of International Child Abduction As Applied to Non-Signatory Nations: Getting to Square One, 20 Hous.
J. Int’l L. 141, 157-58 (1997) (noting problems parents may face when dealing with a country not party to the Hague
Convention).
5 See Hague Convention art. 1 (outlining purpose of Hague Convention).
6 See id. at art. 1 (noting objective of Hague Convention); but see Cardin, supra note 5, at 145 (warning Hague
Convention only empowers courts to decide merits of abduction). The courts located in the child’s habitual residence
determine custody issues. See id. The location where the child resided at the time of the abduction or unlawful retention
determines habitual residence. See Joel R. Brandes and Carol L. Weidman, “Habitual Residence” Under the Hague
Convention, N.Y.L.J., September 23, 1997, at col. 1 (defining habitual residence).
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Former Yugoslav Republic of Macedonia, Malta, Mauritius, Mexico, Monaco, Montenegro,
Montserrat, Morocco, the Netherlands, New Zealand, Norway, Panama, Paraguay, Peru, Poland,
Portugal, Romania, San Marino, Serbia, Slovakia, Slovenia, South Africa, Spain, St. Kitts and
Nevis, Sri Lanka, Sweden, Switzerland, Turkey, Ukraine, the United Kingdom, Uruguay, the
United States, Venezuela, and Zimbabwe.7
The Hague Convention does not act as an extradition treaty, nor does it purport to adjudicate the
merits of a custody dispute.8 It merely provides a civil remedy9 designed to preserve the status
quo by returning an abducted child to the country of his or her “habitual residence” and allowing
the judicial authorities in that country to adjudicate the merits of a custody dispute. As such, the
proceeding is brought in the country to which the child was abducted or in which the child is
retained.10 Although domestic relations involve issues typically governed by state law, the federal
statute implementing the Hague Convention explicitly confers jurisdiction on the federal courts.11
Federal courts are split as to the scope of an appellate court’s jurisdiction once a child has been
returned to his or her country of habitual residence.12 Neither the Convention nor its
implementing law (International Child Abduction Remedies Act or ICARA)13 address the issue of
appellate review or mootness. The U.S. Supreme Court granted review in a case which may have
an impact on subsequent appeals of district court cases under the Hague Convention. In Chafin v.
Chafin,14 the mother returned to Scotland with her daughter pursuant to a district court order
finding that the child’s habitual residence was Scotland. The father appealed the decision to the
11th Circuit. However, applying circuit precedent, the appellate court dismissed the case as moot
as there was no actual affirmative relief available because the child was returned to Scotland. In
the court’s view, any potential remedy would be available to the father in the Scottish courts.
Rights of Custody vs. Rights of Access
Procedures and remedies available under the Convention differ depending on the parental rights
infringed. Under Article 3 of the Hague Convention, the removal of a child is “wrongful” when
“it is in breach of rights of custody attributed to a person, an institution or any other body, either
7 Information obtained from United States Central Authority, Office of Citizens Consular Services, Child Custody
Division at http://travel.state.gov/abduction/resources/congressreport/congressreport_1487.html (last visited December
3, 2012).
8 Article 19 of the Hague Convention states that “[a] decision under this Convention concerning the return of the child
shall not be taken as a determination on the merits of any custody issue.” Id., art. 19, at 1503.
9 The Hague Convention is a “private civil legal mechanism,” and as such, “the parents, not the governments are parties
to the legal action.” Bureau of Consular Affairs, U.S. Dep’t of State, Pub. No. 10489, International Parental Child
Abduction 9 (1997).
10 When a child of a custodial parent in another country is abducted to the United States, the parent has the option of
asking the court in the jurisdiction in which the child is found to enforce the foreign custody degree.
11 International Child Abduction Remedies Act, 42 U.S.C. §11603(a).
12 Bekier v. Bekier, 248 F.3d 1051, 1054 (11th Cir. 2001)(finding that such an appeal is moot and that the court had “no
authority ‘to give opinions on moot questions or abstract propositions ... which cannot affect the matter in issue in the
case before [the Court]’”); see also, Fawcett v. McRoberts, 326 F.3d 491 (4th Cir. 2003)(holding that “[c]ompliance
with a trial court’s order does not moot an appeal [of a Petition for Return of Custody under the aforementioned Acts]
if it remains possible to undo the effects of compliance or if the order will have a continuing impact on future action ...
”).
13 42 U.S.C. §11601 et seq.
14 11-15355-CC slip
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jointly or alone, under the law of the State in which the child was habitually resident immediately
before the removal or retention;” and “at the time of removal or retention those rights were
actually exercised, either jointly or alone, or would have been so exercised but for the removal or
retention.”15
Thus, there are two elements to a claim that the child’s removal was “wrongful” under Article 3:
(1) the removal was in breach of “rights of custody”; and (2) those rights were “actually
exercised” at the time of the removal, or would have been but for the removal.
Article 5 in turn defines “rights of custody,” and distinguishes those rights from “rights of
access”:
(a) “rights of custody” shall include rights relating to the care of the person of the child and,
in particular, the right to determine the child’s place of residence;
(b) “rights of access” shall include the right to take a child for a limited period of time to a
place other than the child’s habitual residence.16
Critically, the treaty provides for the return of the child only if a parent’s custody rights have been
violated.17 Parents deprived of their rights of access have the less robust remedy provided for in
Article 21 of “mak[ing] arrangements” with the Department of State to secure effective exercise
of their rights.18
Countries utilize an array of orders in child custody disputes. Courts must determine whether an
order confers a right of custody or a lesser right of access under the Convention. For example,
until recently, federal courts disagreed on what type of right is conferred by a ne exeat, or “no
exit,” order, which grants one parent the right to veto another parent’s decision to remove their
child from his or her home country. In Abbott v. Abbott,19 the U.S. Supreme Court resolved the
circuit split by finding that such an order confers a right of custody, thus triggering enforceability
under the Convention. In making its decision, the Court relied on the Convention’s text and
purpose to deter child abductions, deferred to the executive branch’s treaty interpretation, and
consulted international case law to establish a uniform interpretation. It is important to note that
the Court’s decision is limited to ne exeat orders. While the ne exeat-physical custody
arrangement is a common one, it is not the only one implemented by courts in child custody
disputes. Therefore, courts will have to address which side of the access-custody line any other
arrangements may fall. The Court also did not address the broader issue of whether the child must
be returned to his home country, instead noting that there are exceptions to the general remedy of
a child’s prompt return.
15 Hague Convention, supra note 6, art. 3. The rights of custody mentioned in subparagraph (a) may arise “in particular
by operation of law or by reason of a judicial or administrative decision, or by reason of an agreement having legal
effect under the law of that State.” Id.
16 Id. at art. 5.
17 Id. at arts. 1 & 3. Parents’ attained custody rights to a child include rights associated with the care of the child and the
right to determine the child’s place of residence. See id. But see Brandes and Weidman (stating the parent does not
need actual custody to use the Convention). A lawful custodian’s denial of association with a child or a breach of a
custody agreement may occur, giving rise to the application of the Hague Convention. The violation of a court decree
does not have to exist for the removal or retention of a child to be considered wrongful under the Hague Convention.
18 Id. at art. 21.
19 130 S.Ct. 1983 (2010).
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Exceptions to a Child’s Prompt Return
The Central Authorities, appointed by each respective signatory nation, cooperate with one
another to discover the location of the wrongfully retained child, to prevent harm to the child, and
to ensure the prompt return of the child. Signatory nations do not have to automatically return the
child to his or her place of habitual residence; discretionary exceptions exist that enable the child
to remain with the removing parent. For example, Article 4 of the Convention establishes that if
the child is over age 16 at the time of the original taking or retention, or becomes 16 at any time
after the taking, the Convention does not apply. Also, if the custody rights involved are those of
visitation (“access,” as they are termed in the Convention), the Central Authority may facilitate
and secure those rights, but under Article 21, a violation of visitation rights does not trigger
procedures to require the child’s return.
Other requests for returns may be affected by discretionary factors. It is within the judge’s
discretionary power under Article 12 to refuse return of the child if the child has become settled
in the new environment and more than one year has passed from the date of the taking or
detention. If more than one year has passed and the reason for the delay was concealment of the
child’s location, the petition to enforce a U.S. custody order may still be considered under the
argument that the one-year limit should be tolled due to the abducting parent’s conduct, as equity
demands no one profit from his or her own wrongdoing.
Discretion is also afforded under Article 13 if the child is deemed mature enough to voice a
preference for staying, or if there is a grave risk of harm to the child if returned. Children as
young as nine have been found mature enough to have their wishes considered.20 Finally, return
may also be refused if it would be against the fundamental principles of human rights and
freedoms in the requested state to return the child. Signatory countries have rendered a wide
variation of decisions interpreting these discretionary criteria.21 There is also a marked variance in
the rate of return among the different signatory countries.22
The Hague Convention attempts to prevent Central Authorities in the requested states from
making judgments based upon cultural principles of the child’s origin country by abandoning the
method of using the child’s “best interests” to justify keeping the wrongfully retained child in the
respective state.23 The Hague Convention bases its terms on civil, not criminal international law,
and therefore criminal liability and extradition provisions do not fall within its scope.24
20 See S v. S. [1993] 2 F.L.R. 492 (C.A.) (English decision refusing to return child to France).
21 See Linda Silberman, Hague Convention on International Child Abduction: A Brief Overview and Case Law
Analysis, 28 Fam. L.Q. 9, 24 (1994).
22 See Linda Girdner and Janet Chiancone, A.B.A. Ctr. on Children and the Law, Survey of Central Authorities of the
Hague Convention on the Civil Aspects of International Child Abduction (1997) (showing successful return rate
varying from 5% (Finland) to 95% (Luxembourg)).
23 See Dorothy Carol Daigle, Note, Due Process Rights of Parents and Children in International Child Abductions: An
Examination of the Hague Convention and Its Exception, 26 Vand. J. Transnatl L. 865, 869 (1993) (noting how
automatic return of child tries to prevent value judgments about state).
24 See Finan, supra note 5, at 1013 (clarifying Hague Convention not grounded in criminal law). Punishment of the
abductor is not the Hague Convention’s purpose; its main concern focuses on having the wrongfully removed child
placed back in his or her original situation before the removal by denying the abductor any legal advantage from the
retention of the child in another signatory state.
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Although the Hague Convention contains certain limitations, it apparently offers the greatest
chance for a prompt return of a wrongfully removed child. The difficulty with parental
international child abductions lies in the fact that many countries do not participate in the Hague
Convention, and when a parent takes a child to a non-Hague contracting state, governments of the
nations involved are not obligated to assist in the child’s return. Some countries refuse to
participate in the Hague Convention because they do not believe in the automatic return of the
child; rather they presume that the determination of the child’s best interests should occur within
their own jurisdiction and under their own laws.25 An analysis of the child’s best interests
considers the religious and social values of the respective countries involved, but religious and
cultural tensions between these countries and Western-culture family law often render
negotiations nearly impossible.26
Current U.S. Laws
Law enforcement in the United States historically viewed parental kidnapping as a private family
matter that did not require outside involvement. This belief has changed, resulting in the
enactment of several laws that recognize the seriousness and criminality of parental
kidnappings.27 Presently, law enforcement agents with arrest warrants seek out parents who have
violated a custody decree by taking a child out of the state or country. Difficulties arise when
parents take children out of the country because foreign courts have no obligation to enforce
American custody decrees or abide by American laws. Even though the United States has
difficulty enforcing parental kidnapping laws abroad, these laws can act as useful mechanisms to
facilitate solutions to international child abductions.
International Child Abduction Remedies Act (ICARA)28
On April 29, 1988, the same day the United States became a signatory to the Hague Convention,
Congress enacted the International Child Abduction Remedies Act (ICARA).29 ICARA empowers
state and federal courts to hear cases under the Convention and allows the Central Authority
access to information in certain American records regarding the location of a child and abducting
parent. In the United States, the Office of Children’s Issues (OCI) in the Department of State
serves as the Central Authority in instances where children are wrongly removed from the United
States. A parent seeking the return of a child who the parent claims has been wrongly abducted
may apply to the “Central Authority” of the child’s habitual residence or of any other signatory
nation to the Hague Convention.30 Unfortunately, the Hague Convention and ICARA cannot
25 Carol S. Bruch, Religious Law, Secular Practices, and Children’s Human Rights in Child Abduction Cases Under the
Hague Child Abduction Convention, 33 N.Y.U. J. Int’l. & Pol. 49, 51-53 (discussing the difficulties between Western
countries and Islamic nations when negotiating child custody disputes because of the sensitivity surrounding the
differing religious and social aspects of the cultures involved).
26 Id.
27 As of July 2001, as provided by P.L. 106-113, Section 236, both parents or legal guardians are required to execute a
passport application for a minor child under age 14. In addition, the person executing the application must provide
documentary evidence demonstrating that the individual has either (1) sole custody of the child or (2) consent of the
other parent to the passport’s issuance. 22 U.S.C.A. §213.
28 42 U.S.C. §11601 et seq.
29 42 U.S.C. §11601(a).
30 Hague Convention, art. 6, at 1501.
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function as remedies in a situation that involves a nonsignatory nation of the Hague Convention,
and U.S. courts have dismissed complaints made under ICARA for failure to state a claim
because of the involvement of a nonsignatory nation.31
International Parental Kidnapping Crime Act (IPKCA)32
The International Parental Kidnapping Crime Act (IPKCA) criminalizes the removal of a child
from the United States with “the intent to obstruct the lawful exercise of parental rights.” The
term “parental rights” refers to the right to joint or sole physical custody of a child obtained
through a court order, a legally binding agreement between the involved parties, or by operation
of law.33 A parent can use IPKCA as an affirmative defense, and it will not detract from the
provisions of the Hague Convention.34 Defendants have challenged the constitutionality of
IPKCA, questioning the vagueness of the act and claiming that it violates the free exercise of
religion, but U.S. courts have upheld it.35
IPKCA may provide the potential to prosecute wrongful acts of parents, but it cannot guarantee
the return of children from foreign countries where their parents wrongfully removed them. For
example, in United States v. Amer,36 Ahmed Amer abducted his two children to Egypt and was
given custody in an Egyptian court. His wife, who previously had been given custody in a U.S.
court,37 filed a complaint with the Federal Bureau of Investigation (FBI).38 Upon Ahmed’s return
to the United States, he was arrested on charges of international parental kidnapping in violation
of IPKCA.39 Ahmed was sentenced to 24 months’ imprisonment and a one-year term of
supervised release under the special condition that he return the abducted children to the United
States.40 When Ahmed began his supervised release term, he expressed an unwillingness to return
his children to the United States.41
31 See Mezo v. Elmergawi, 855 F. Supp. 59 (E.D.N.Y. 1994) (discussing now ICARA and Hague remedies do not apply
to non-signatories).
32 18 U.S.C. §1204 (explaining what constitutes a criminal act under IPKCA). Violating the statute subjects the
perpetrator to a fine, imprisonment of not more than three years, or both. Id.
33 See id. (defining the term “parental rights”).
34 See id. (outlining affirmative defense and boundaries of IPKCA). Affirmative defenses under IPKCA are (1) the
defendant acted pursuant to a valid court decree under UCCJA; (2) the defendant was escaping domestic violence; (3)
the defendant had lawful physical custody of the child and failed to return the child because of circumstances beyond
his or her control, and the parent made an attempt at reasonable notice to the other parent within 24 hours. See id.
35 See United States v. Fazal-Ur-Raheman Fazal, 203 F.Supp. 2d 33, (D. Mass., 2002) (finding that IPKCA was
constitutionally valid under a rational basis analysis); see also, United States v. Amer, 110 F.3d 873, 879 (2d Cir. 1997)
(rejecting the challenge that IPKCA violates the free exercise clause because it is a neutral law of general application
that “punishes parental kidnappings solely for the harm they cause”).
36 110 F.3d 873, 873 (2d Cir. 1997).
37 See id.
38 See Brief for the United States at 4-5, United States v. Amer, 110 F.3d 873 (2d Cir. 1996) (No. 96-1181).
39 See id. at 7.
40 See id. at 14.
41 See Transcript of the Hearing at 9, 23, United States v. Amer, 110 F.3d 873 (2d Cir. 1996) (CR-95-693 (CBA)).
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Fugitive Felon Act42
The Fugitive Felon Act enhances states’ abilities to pursue abductors beyond state and national
borders by permitting the FBI to investigate cases that would otherwise fall under state
jurisdiction. The act also authorizes the use of Unlawful Flight to Avoid Prosecution (UFAP)
warrants in parental kidnapping cases.
Extradition Treaties Interpretation Act of 198843
The Extradition Treaties Interpretation Act of 1988 authorizes the United States to interpret
extradition treaties listing “kidnapping” as encompassing the offense of parental kidnapping.
Admiral James W. Nance and Meg Donovan Foreign Relations
Authorization Act, Fiscal Years 2000 and 200144
Section 236 of the Admiral James W. Nance and Meg Donovan Foreign Relations Authorization
Act, Fiscal Years 2000 and 2001, requires both parents or legal guardians to execute a passport
application for a minor under age 14.45 In addition, the individual executing the application must
provide documentary evidence demonstrating that the individual has either (1) sole custody of the
child or (2) the other parent’s consent to the passport’s issuance.46 However, it should be noted
that passport controls may be ineffective under some circumstances, as some abductors are dual
nationals or citizens of the country to which they are returning. Therefore, the child may also be a
citizen of the other country. If a dual national, the child is eligible for passports from both the
United States and the other country of nationality.
Immigration and Nationality Act (INA), as Amended47
The Immigration and Nationality Act (INA) provides that any alien who, in violation of a custody
order issued by a U.S. court, takes or retains a child out of the United States, may be excluded
from the United States. The exclusion applies only to aliens, not to U.S. citizens, and does not
apply if the child is taken to or kept in a county that has ratified the Hague Convention. The
exclusion ceases to apply when the child is surrendered. This exclusion can also be applied to
relatives or friends who assist in keeping the child abroad. This act may give the U.S.-based
parent leverage in negotiating for the child’s return if the alien parent needs to reenter the United
States for any reason.
42 18 U.S.C. §1073.
43 Note 18 U.S.C. §3181.
44 P.L. 106-113.
45 Note 22 U.S.C. §213.
46 22 U.S.C. §213.
47 8 U.S.C. §1182(a)(10)(C)(i).
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Author Contact Information
Alison M. Smith
Legislative Attorney
amsmith@crs.loc.gov, 7-6054
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