District Court Cases in Districts other than New York Published in 2025 (Continued, see infra ) updated10.19.25

 Khan v Seemab, 2025 WL 2582897 (United States District Court, E.D. Pennsylvania, 2025)

[Qatar] [Habitual residence] Petition dismissed for lack of jurisdiction] [Qatar not a signatory to Convention]

 

Tsuruta v Tsuruta, 2025 WL 2912271 (United States District Court, E.D. Missouri, 2025)

[Japan] [Motion for Relief from Judgment pursuant to Rule 60(b) of the Federal Rules of Civil Procedure denied].

 

Higuera v Jiminez, 2023 WL 12156566 (United States District Court, N.D. Georgia, 2023)

[Venezuela] [Petition granted] [habitual residence] [Grave risk of harm not established]

 

Deravil v. Jean ,2025 WL 2906673 (United States District Court, S.D. Ohio, 2025)

[Martinique] [Petition granted] [motion to restore a preliminary injunction after the entry of final judgment while appealing that final judgment denied]

 

Deravil v. Jean, 2025 WL 2904884 (United States District Court, S.D. Ohio, 2025)

[Martinique] [Deravils Motion in limine to exclude these experts’ reports and testimony denied and for summary judgment denied. Jean-Louises motion for Summary Judgment Granted;  Deravils’ Petition for A.D.’s return to Martinique for the pendency of any associated custody claims or determinations Denied.]

Deravil, v. Jean 2025 WL 2903662 (United States District Court, S.D. Ohio, 2025)

[Martinique] [ Motion requesting Court to conduct an in camera interview granted]

 

Boa-Bonsu v. Owusu, 2025 WL 2896377 (United States District Court, S.D. Ohio, 2025)

[Finland] [Petition denied] [Habitual residence] [Wishes of the child defense established]

 

Karlevid v Slotto,  2025 WL 2753549 (United States District Court, D. Massachusetts, 2025)

[Sweden][Petition granted][Habitual residence][Grave risk of harm defense not established][even if such a finding were appropriate, the Court would not exercise its discretion to deny removal on that basis].

 

Peled v Peled, 2025 WL 2711374 (United States District Court, S.D. Ohio, 2025)

[Israel] [Motion to dismiss for lack of subject matter jurisdiction granted] [Children were not located in Ohio, or anywhere in the United States, when Plaintiff initiated this action.]

 

Gaston v Gutierrez, 2025 WL 2694981 (United States District Court, M.D. Florida, 2025)

[Peru][Motion for Attorneys fees and expenses] [Recommended award attorney’s fees of $6,867.00, court costs of $405.00, and other necessary expenses of $930.58.}

 

Aubert v Poast, 2025 WL 2671697 (United States District Court, W.D. Wisconsin, 2025)

[Norway] [Petition denied] [Grave risk of Harm Defense established].

 

DaSilva v DaSilva, 2025 WL 2607879 (United States District Court, D. Massachusetts, 2025)

[Brazil] [After reversal of return order by First Circuit, upon remand to determine whether Child. should nevertheless be returned to Brazil.(Rodrigues v. Silveira, 141 F.4th 355, 366 (1st Cir. 2025). the Court declined to exercise its discretion to return and denied the petition.]

 

 

Khan v Seemab, 2025 WL 2582897 (United States District Court, E.D. Pennsylvania, 2025)

[Qatar] [Habitual residence] Petition dismissed for lack of jurisdiction] [Qatar not a signatory to Convention]

 

Arabi v Kerroum, 2025 WL 2267991 (United States District Court, N.D. Georgia, 2025)

[Morocco] [Motion for Attorney Fees and Costs and Expenses granted in part.][ Petitioner awarded $26,610.10 in fees and expenses].

 

Boa-Bonsu, v. Owusu, 2025 WL 2305880 (United States District Court, S.D. Ohio, ,2025)

 [Petitioners) motion to strike the Defendant/Respondent Deborah Owusu’s  fifth affirmative defense. which asserts: “Petitioner is estopped from asserting claims under the Hague Convention due to prior conduct that misled Respondent into believing the removal was permitted.” The Hague Convention provides for limited defenses, and courts hold that estoppel is not among them. Petitioner’s Motion to Strike  was granted]

 

Dhooge v Pronker, 2025 WL 2375385 (United States District Court, E.D. Arkansas, 2025)
[Netherlands] [Petition granted] [Petitioner established that J.D. was wrongfully removed ]. [Respondent failed to establish one of the defenses] [The Court recognized the July 15, 2025 custody determination of the Dutch court,]

Dumitrascu v Dumitrascu, 2025 WL 2223027 (United States District Court, D. Colorado, 2025).

[Romania} [defendant’s motion to transfer venue; motion to transfer the case to another judge; motions seeking relief under Federal rules; motions for criminal and civil contempt; and motion for a preliminary injunction denied].

 

 

Goderth v Yandall- Goderth,  2025 WL 1866307 (United States District Court, N.D. Illinois, 2025)

[Germany] [Petition denied] [Habitual residence established] [Children are well-settled in the U.S.]

Giguere v Tardif, 2025 WL 2452168 (United States District Court, D. Massachusetts, 2025).

[Canada] [Petition granted] [Children’s habitual residence as of August 28, 2024, was Canada] [Consent prior to the time of retention was no defense][ Petitioner’s participation in Massachusetts  divorce action did not constitute subsequent acquiescence in the retention of the Children]

 

Horcajo v Benaye, 2025 WL 2171598(United States District Court, S.D. Florida, 2025)
[Spain] [Petition denied][Removal was wrongful because Spain was the habitual residence of the Children prior to their removal; emoval was in breach of custody rights under Spanish law; and Petitioner was exercising his rights as defined by the Hague Convention. Respondent, proved by clear and convincing evidence that the Children would face a grave risk of danger if returned to Spain because of Llorente’s domestic violence and associational criminal risk, and she had proven by a preponderance of the evidence that the Children were well-settled in their new environment.]

 

Pits v Gonzalez,  2025 WL 2434240, United States District Court, N.D. California,2025.
[Germany] [Motions for summary judgment ][ Motions were denied as to the core issue of whether the children were habitual residents of Germany at the time of their removal and return to the United States. Petitioner’s Motion was granted with respect to summary adjudication that if the children were habitual residents of Germany, Petitioner had and was exercising rights of custody under German law immediately prior to the children’s removal.]

 

Schwaneberg, v. Lopez, 2025 WL 2085531 (United States District Court, W.D. Virginia, 2025]  [South Korea][Motion for Attorney Fees and Costs after prevailing on petition.]  The court awarded $73,215.00 in attorney’s fees. Petitioner failed to show that $8,558.77 request for local counsel attorney fees and that the $4,000.00 request for Korean counsel attorney fees was reasonable. As a result, the court discounted the request by 50%, or $2,000.00 and $4,279.39 because not enough information was supplied by petitioner to support the award). The court awarded $12,618.83 in costs.]

 Harvey v Means, 2025 WL 2443151 (United States District Court, W.D. Washington, 2025). [Scotland] [Motion for appellate attorneys’ fees.] [ Harvey prevailed in the district court and on appeal, and was awarded $50,000 in appellate attorneys’ fees.]

 Torres v Pastor, 2025 WL 2425278 (United States District Court, W.D. Louisiana, 2025)[Brazil] [Motion for Necessary Fees and Expenses] 9Petitioner’s attorney’s fees and costs of $33,865.12 are reasonable. Considering the financial status of both parties and the facts in this case, Respondent’s obligation was reduced to 90% of Petitioner’s attorney’s fees and costs, or $30,478.61]

Gomez v Gonzalez, 2025 WL 1666243, W.D. Washington, 2025]
[Mexico] [Petition granted] [Attorney’s fees] [granted in part] [80% reduction proportionate to Respondent’s inability to pay]

Lee v Curcio, 2025 WL 1549318 (S.D. Florida, 2025)
[Brazil] [Habitual residence] [Petition denied]

Mendez v Brandon, 2025 WL 1532583 (W.D. Kentucky,2025)
[Japan] [State court already ruled on wrongful retention claim] [ Motion to dismiss granted] [ Younger and Colorado River abstention]

Gomez v. Ramirez, 2025 WL 1415905 (E.D. Pennsylvania, 2025).

[Guatemala] [Petition denied] [habitual residence] [well-settled affirmative defense applies]

Edelstein V. Nelson, 2025 WL 1419962 (D. Nevada, 2025).
[Argentina] [Habitual residence] [Report & Recommendation to deny petition adopted]

 Edelstein v Nelson, 2025 WL 1610564 (D. Nevada, 2025)[Argentina] [Habitual residence not established] [consent and acquiescence ][Recommendation that Petition be denied]

 Muehlbauer V. Muehlbauer, 2025 WL 1392571, E.D. Missouri, 2025)[Switzerland][ Motion to Exclude expert Testimony under Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (1993) and Federal Rules of Evidence 702, 401, and 403. Rule 702 denied.

Ciampa v Nichols, 2025 WL 1358488 (C.D. California, 2025)

[Italy] [Motion for Attorney Fees and Costs granted as requested, $144,768 in attorney’s fees and costs and $15,328 in personal expenses. Counsel, charged a rate of $650 per hour]

Paplaczyk v Paplaczyk,2025 WL 1296177 (S.D. Georgia, 2025)
[Germany] [Petition for Enforcement of German Order][sua sponte dismissal for lack of federal jurisdiction where children not located in the United States]

Giguere v. Tardif, 2025 WL 1293364 ( D. Massachusetts, 2025)

[Canada][Motion to dismiss for lack of subject matter jurisdiction and failure to state a claim denied]

Blasi v.Dunnagan, 2025 WL 1262062 (E.D. North Carolina, 2025).
[Thailand] [Motion for abstention under Younger v. Harris, 401 U.S. 37 (1971) denied]

Armand v Armand, 2025 WL 1249420 (E.D. Missouri, 2025)
[France] [Petition granted] [habitual residence] [ Grave risk of harm defense not established]

Kelly v Turner, 2025 WL 1202043 (D. Oregon, 2025)

[Mexico] [Petition denied] [Defense of Grave risk of physical or psychological harm based on spousal abuse established]

Gamboa v Williams, 2025 WL 1195567 ( S.D. Texas, 2025)

[Colombia][Petition granted] [Attorneys fees of $67,647.75 and costs and fees of $5,835.71 awarded with  post-judgment interest]

Loncarevic v Loncarevic, 2025 WL 1167564 (S.D. Texas, 2025)
[Germany] Petition granted] [Attorneys fees of $58,497.14 awarded with post-judgment interest]

Alvarez v Marin, 2025 WL 1091940 (C.D. California (2025)
[Mexico] [Petition granted] [judgment on default]

 Aubert v Poast, 2025 WL 1071672 (W.D. Wisconsin, 2025).
[Norway] Motion to dismiss denied] [Motion for video and in-person visitation during the pendency of the case granted]

 Ballesteros v Ruiz, 2025 WL 1068855 ( N.D. Illinois, 2025)
[Canada][Motion to enforce oral settlement agreement granted]

 Parra v Camargo, 2025 WL 992581, United States District Court, N.D. Texas (2025)
[Chile][Petition granted][Habitual residence][Grave risk of harm defense not established]

Gomez v Gonzalez, 2025 WL 835013 (United States District Court, W.D. Washington, 2025).[Mexico] [Petition granted] [Habitual residence][ Grave risk of harm defense not established]

Basset v. Dana, 2025 WL 742759 (United States District Court, S.D. Florida.,2025)

[Israel] [Petition granted] [ Habitual residence] [Respondent failed to establish consent or acquiescence, grave risk of harm, fundamental principles and mature child defenses]

Elkhaiat v Mawashi, 2025 WL 711949 (United States District Court, D. Arizona, 2025).[Canada][Habitual residence][Consent defense not established] [Grave risk defense not established][ ameliorative mitigation measures appropriate]

 Yuriiovych v Hryhorivna, 2025 WL 660634, United States District Court, D. Montana, 2025)

[Ukraine][Attorneys Fees and Costs] [attorney fees of $82,235.00 and costs of $6,601.84 awarded]