Ms Langley with Teertha Gupta following her presentation at the Centre for Family Law and Practice in London.

Family Law International News

  • The primary concern expressed by Japan to signing the Hague Convention is that Japanese women and their children will be left vulnerable to abusive foreign husbands. In contrast, Singapore and South Korea appear poised to accede to the Convention.
  • Protecting Kids: Rethinking the Hague Convention
    A new study by Jeffrey Edleson and Taryn Lindhorst indicates that more than two-thirds of international child abductions are perpetrated by women. Edleson, a professor of social work at the University of Minnesota reports that in a majority of cases, these women are fleeing abusive husbands. He also argues that the United States and international community should begin considering the impact of domestic violence in determining whether to compel
    a child's return.
  • U.S. Signature of the Child Protection Convention
    Secretary of State Hillary Rodham Clinton has recently announced that the United States has signed the Convention on Jurisdiction Applicable Law, Recognition, Enforcement and Co-operation in Respect of Parental Responsibility and measures for the Protection of Children. This agreement has significant implications for kidnapped children and international family law by ensuring international recognition and enforcement of child custody and visitation orders.
  • More countries join fight against Japan in child custody abduction cases
    Japan’s Minister of Justice recently met with representatives of several members of the Hague Convention on the Civil Aspects of International Child Abduction to discuss Japan’s possible signing of the Convention. Presently, foreign parents have no parental custody rights to abducted children residing in Japan.
  • Report: DOD to give more help to troops in international child-custody disputes
    The Department of Defense has recently agreed to provide increased international family law assistance to military personnel grappling with the complexities of international divorce and international custody disputes.
  • New law could help service members whose children have been abducted
    Representative Chris Smith of New Jersey has introduced a bill to establish protocols to prevent international abduction and assist the families of kidnapped children.
  • Breaking Impasse over Child Abduction
    Representatives James Moran of Virgina, and Christopher Smith of New Jersey have successfully enacted House Resolution 1326, calling on the Government of Japan to immediately address the growing problem of abduction to and retention of United States citizen minor children in Japan.
  • Japan and International Parental Kidnapping House Resolution 1326
  • Symposium on International Parental Child Abduction, Tokyo 2009

Speaking Engagements

Family Law International will be speaking and presenting at the following events:

Traversing the Trial of Alienation

  • Where: Annual Conference of the AFCC (Association of Family and Conciliation Courts), 2-5 June, 2010, Denver, Colorado, USA
  • Our Presentation: "International Parental Child Abduction"
  • Download Brochure: AFCC.pdf

International Child Abduction, Relocation and Forced Marriage

  • Where: Centre for Family Law and Practice's Inaugural Conference, 30 June – 2 July 2010, London, England
  • Our Presentation: "Mediating International Parental Kidnapping Cases in the United States: Ethical and Practical Considerations for Mediators on the Front Lines" with Professor J. Zawid
  • Download Brochure: CFLP.pdf


Case Law Update

  • Karpenko v. Leendertz.pdfKarpenko-v.-Leendertz

    On August 24, 2010, the Court of Appeals for the Third Circuit issued its ruling in Karpenko v. Leendertz, upholding the District Court Order to return the minor child to the Netherlands. Father had obtained a Pennsylvania State Court vesting him with sole custody, and had travelled to the Netherlands and snatched the child off the street, driven to Germany, flown to Dubai, and then back to the United States. Mother filed a Petition for Return of the Child in Federal District Court which was granted. On appeal, Father argued, inter alia, that Mother should be denied equitable relief under the Hague Convention on the Civil Aspects of International Child Abduction because she had "unclean hands." Father argued that she had interfered with his visitation rights and therefore her prior acts of bad faith should prohibit her rights to seek relief in a court of equity. The majority held that the Convention's purpose is to "protect the well being of children" and the application of the unclean hands doctrine would undermine this goal. In a vigorous dissent the argument is made the unclean hand doctrine should apply in these cases. This is an interesting topic to watch for in other Circuits, and a novel defensive argument.

  • Abbott v Abbott, U.S. Supreme Court No. 08-645

  • A recent decision (April 2010) around criminal charges, extradition and child abuction. Re: (on the application of Prosser) v. Secretary of State for the Home Department This case is regarding a claimant's extradition to United States of America sought in respect of offences of fraud and child abduction - Claimant suffering from several conditions including severe depression and fibromyalgia.

Back to top