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Chafin v. Chafin

568 U.S. 165 (2013)

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Chafin v. Chafin

United States Supreme Court

568 U.S. 165 (2013)

Facts

The United States signed a treaty on child abduction, and Congress passed implementing legislation known as the International Child Abduction Remedies Act (ICARA). ICARA called for all children to be immediately returned to their country of habitual residence if they had been wrongfully removed. Jeffrey Lee Chafin (defendant), a U.S. citizen, and Lynne Hales Chafin (plaintiff), a noncitizen, gave birth to a daughter, E.C. Both parents spent time in America as well as countries across Europe. The couple divorced in the United States, and Lynne was deported after an arrest for domestic violence. Lynne sued in federal district court under ICARA, claiming that Scotland had been E.C.’s country of habitual residence. The district court ruled in Lynne’s favor. It also awarded attorney’s fees to Lynne. Lynne departed for Scotland with E.C. hours later. A Scottish Court later granted Lynne interim custody of E.C. Jeffrey appealed the case to the circuit court, which held that the case was moot because E.C. was already in Scotland and so the court was unable to grant relief. Jeffrey appealed to the Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Roberts, C.J.)

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