On June 15, 2022, the Supreme Court of the United States unanimously held that in cases under the Hague Convention on the Civil Aspects of International Child Abduction (the Hague Convention), once a finding is made that returning a child to a parent residing in a foreign country would expose the child to a "grave risk of harm," the court may refuse to return the child without considering whether any "ameliorative measures" may be implemented in that foreign country to mitigate the risk of harm. Golan v. Saada, 596 U.S. ___ (2022). This decision brings to an end a long-term split among the U.S. federal circuit courts, where some courts required a mandatory consideration of ameliorative measures post finding of the grave risk of harm and others expressly refused to do so. Most significantly, for the first time, the Supreme Court explicitly held that "the Convention sets as a primary goal the safety of the child." In doing so, the Supreme Court rejected the long-held view of some federal circuit courts that the Convention "pursue[s] return exclusively or at all costs."