In Re: Private Complaint Filed by Luay Ajaj

2021 Pa. Super. 28, 253 A.3d 722
CourtSuperior Court of Pennsylvania
DecidedFebruary 25, 2021
Docket3421 EDA 2019
StatusPublished
Cited by2 cases

This text of 2021 Pa. Super. 28 (In Re: Private Complaint Filed by Luay Ajaj) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re: Private Complaint Filed by Luay Ajaj, 2021 Pa. Super. 28, 253 A.3d 722 (Pa. Ct. App. 2021).

Opinion

J-A27003-20

2021 PA Super 28

IN RE: PRIVATE COMPLAINT FILED BY IN THE SUPERIOR COURT LUAY AJAJ OF PENNSYLVANIA

APPEAL BY: COMMONWEALTH OF PENNSYLVANIA

No. 3421 EDA 2019

Appeal from the Order Entered October 31, 2019 In the Court of Common Pleas of Montgomery County Criminal Division at Nos: CP-46-MD-0001539-2019, CP-46-MD-0001539-2019

BEFORE: STABILE, J., NICHOLS, J., and COLINS, J.*

OPINION BY STABILE, J.: Filed: February 25, 2021

The Commonwealth appeals from the October 31, 2019 order entered

in the Court of Common Pleas of Montgomery County overturning the

Commonwealth’s disapproval of a private complaint filed by Luay Ajaj (“Ajaj”).

Ajaj filed the private complaint seeking charges against his wife (“Mother”) for

violations of 18 Pa.C.S.A. § 2904(a) (interference with custody of children)

and § 2909(a) (concealment of whereabouts of a child). The Commonwealth

disapproved the complaint, initially citing “evidentiary issues.” However, at

the time of the hearing on the matter, the Commonwealth argued “policy

____________________________________________

* Retired Senior Judge assigned to the Superior Court. J-A27003-20

considerations.” The Commonwealth asserts the trial court abused its

discretion by overturning the disapproval. Following review, we affirm.

While the underlying facts themselves are somewhat complicated, they

are further complicated by the state of world affairs. Essentially, after the

court awarded Ajaj custody of his two children, he filed a private complaint

charging Mother with interfering with their custody and concealing their

whereabouts “by hiding them away in the war-torn country of Iraq contrary

to orders of this court conferring sole legal and physical custody of the children

on Ajaj, issuing bench warrants for [Mother], and directing all agencies of law

enforcement to cooperate in securing the children’s return.” Trial Court

Opinion 5/8/20, at 1 (some capitalization omitted).

The trial court provided the following factual and procedural

background:

Ajaj instituted this action in this court on June 26, 2019, by petition under [Pa.R.Crim.P.] 506(B)(2), for review of the District Attorney’s disapproval of Ajaj’s private criminal complaint. The petition, however, was not the beginning of Ajaj’s struggle to attain the return of his purloined children, but the last straw in a long and tortuous process . . . to bring them home from one of the most perilous countries on Earth. . . .

The current saga began in August 2017, when the mother of the two children, then approximately one and four years old, left with them and [Ajaj] from the home in West Norriton, Pennsylvania, where the family, all United States citizens, had lived since the children’s birth, on a trip to Iraq. While there, she and her uncles took the children away to an undisclosed location. Ajaj has been on an unfailing quest to get them back ever since.

Following the trail of the somewhat disjointed pro se narrative and exhibits of the private criminal complaint attached to Ajaj’s

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petition . . . , this lower court pieces together that to get his children back Ajaj first consulted with American authorities in Iraq, where his life was being threatened by the mother’s powerful uncles and other third parties. Ajaj had a meeting with the office of American Citizen Services of the United States Embassy in Baghdad, Iraq (where he believed the mother still to be with the children) on September 12, 2017.

Unsuccessful there, he returned home, retained counsel, and broadened his outreach stateside to the United States Department of State’s passport center, Diplomatic Security Service, and Office of Children’s Issues, later repeating his foray to the U.S. Embassy in Baghdad in August 2018. Based on these contacts and meetings, on September 17, 2018, the Office of Children’s Issues opened a case file and, through Soren Andersen, “the Country Officer in the Office of Children’s Issues responsible for outgoing cases of international parental child abduction to Iraq,” wrote Ajaj a letter listing resources to help him in resolving the crisis.

Id. at 2-3 (citations to exhibits and some capitalization omitted).

The letter from Sorensen to Ajaj outlined options available to Ajaj,

including filing for custody in the United States and seeking recognition of a

custody order in Iraq; filing for custody in Iraq; or consulting with law

enforcement authorities about potential criminal remedies, noting his office

“can assist you with communicating with law enforcement, should you decide

to pursue criminal warrants against your children’s mother.” Id. at 3 (quoting

Sorensen’s September 17, 2018 letter to Ajaj). Sorensen also recommended

filing a missing persons report as a first step to any of the available options

as a means of documenting the children’s retention by Mother. Id.

While seeking advice from various agencies and entities, on September

27, 2018, Ajaj also filed an emergent petition for custody of the children in

the Family Division of the Montgomery County Court. On October 1, 2018,

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that court entered an order deeming the matter an emergency and granting

sole legal and physical custody to Ajaj pending a full hearing upon the

children’s return. The court scheduled additional proceedings, at which

Mother did not appear, and ultimately issued a bench warrant for Mother’s

arrest and affirmed the award of sole legal and physical custody to Ajaj.

The trial court summarized various legal proceedings and developments

that occurred between September 2018 and May 2019, id. at 5-13, including

the issuance of an order in the domestic proceedings that directed

Montgomery County law enforcement agencies to cooperate in the capture of

Mother and the return of the minor children. Id. at 13 (citing order dated

5/31/19 and entered 6/3/19).

On May 31, 2019, Ajaj filed his private criminal complaint with exhibits,

seeking to charge Mother with the offenses noted above, i.e., interference

with custody of children and concealing the whereabouts of children. As this

Court reiterated in In re Hamelly, 200 A.3d 97 (Pa. Super. 2018), “A private

complaint must at the outset set forth a prima facie case of criminal conduct.”

Id. at 101 (quoting In re Ullman, 995 A.2d 1297, 1213 (Pa. Super. 2010)).

“The district attorney must investigate the allegations of a properly drafted

complaint to permit a proper decision on whether to approve or disapprove

the complaint.” Id. (citing Ullman, 995 A.2d at 1213).

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On June 19, 2019, the District Attorney’s Office issued its disapproval of

the complaint, citing “evidentiary issues.”1 Because the disapproval was

based on evidentiary issues, on June 26, 2019. Ajaj filed a petition for de novo

review of the disapproval. The court scheduled a July 23, 2019 hearing on

the petition.2

On the day of the hearing, the District Attorney’s Office (hereinafter

referred to as “the Commonwealth”) filed an answer to the petition in which it

asserted for the first time that the complaint was properly disapproved, not

only for evidentiary issues, but also for policy considerations. The

Commonwealth then argued policy considerations at the hearing.3 Those

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Related

In Re: Private Comp. Filed by L. Ajaj Apl of Com.
Supreme Court of Pennsylvania, 2023
In Re: Private Complaint Filed by Luay Ajaj
2021 Pa. Super. 28 (Superior Court of Pennsylvania, 2021)

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Bluebook (online)
2021 Pa. Super. 28, 253 A.3d 722, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-private-complaint-filed-by-luay-ajaj-pasuperct-2021.