Joanne S. Adams (petitioner) sought to move from California to Ohio with her son, Russell. At a subsequent custody hearing, full physical and legal custody of Russell was awarded to Joanne and Russell’s father, William Young, was given visitation for two weeks during the Christmas holiday and Easter weekend the following year. That year, William told Joanne that he wanted to have Russell with him during the Christmas holiday and purchased a round-trip ticket for him. Joanne, however, refused to allow Russell to go. Joanne was subsequently found in contempt by a California court and, at that hearing, custody of Russell was awarded to William. William sought to enforce the California court’s contempt order in Ohio. The Ohio court held that California had properly exercised jurisdiction over the parties and subject matter and could not take jurisdiction. Joanne then appealed to the Ohio Court of Appeals. In 1988, the appellate court held that the California order was not enforceable in Ohio because Joanne had not received proper notice of the hearing. Thereafter, Joanne relinquished custody of Russell to William. A municipal court in Santa Clara, California, then issued an arrest warrant for Joanne alleging she violated California Penal Code § 278.5(b). Joanne was arrested and detained pursuant to an arrest warrant issued by the Governor of Ohio alleging she was an “alleged fugitive from justice, who stands charged…in California with detention or concealment of a child in violation of a custody order.” Joanne filed a petition for a writ of habeas corpus which was denied by the trial court. Joanne appealed.