In the recent case of Sosa v. Pena, the Third District Court of Appeal addressed jurisdictional issues related to child custody determinations.

The U.S. Supreme Court issued a unanimous opinion authored by Justice Sonia Sotomayor, in which the Court ruled that U.S. Courts can refuse to return children to their home countries where there is a risk of harm without considering all ameliorative measures that could potentially reduce that risk of harm.