Comity Without Reciprocity: Orders Concerning International Child Custody & Ground Reality
The author writes "When a child has been wrongfully removed from the U.S., a parent would typically look to secure a custody/return order from a U.S. court. However, when enforcing that order in a foreign country, the harsh truth remains that foreign countries are sovereign entities and not required to recognize or defer to a U.S. family court's jurisdiction or custody decision."
January 13, 2025 at 10:00 AM
3 minute read
When a child has been wrongfully removed from the U.S., a parent would typically look to secure a custody/return order from a U.S. court. However, when enforcing that order in a foreign country, the harsh truth remains that foreign countries are sovereign entities and not required to recognize or defer to a U.S. family court's jurisdiction or custody decision. At best, a U.S. custody order will be one of several factors, including age, gender, nationality and (at times) religion of the child among others, that foreign courts consider when making a de novo child custody determination. In fact, factors like comity are often held by foreign courts as subservient to the best interest of the child.
What is comity? It’s the recognition of one country’s judicial acts by the other. For the principle of comity to be effective, reciprocity in recognizing the judgments of the other international court is essential. In other words, there is no comity without reciprocity. This balance of comity appears particularly lopsided in the realm of international child custody because there is an evident lack of reciprocity between the United States and other countries. This causes concern because the U.S. is home to more international migrants than any other country.
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