In re ICJ (2021)

Partly overruled (Golan v. Saada, U.S. 2022); International father's termination of financial support for child is not sufficient to establish abandonment of the child; Family court erred when, after finding that father's custody posed "grave risk" to child, it did not consider whether there were alternative remedies sufficient to permit child's return to foreign country for custody determination by that country's courts; Court also erred by denying child's return based on COVID without evidence in record indicating COVID's risk to the child