Royal Borough of Kensington and Chelsea v. Tara Bafna-Louis

CourtCourt of Appeals for the Second Circuit
DecidedSeptember 22, 2023
Docket23-470
StatusUnpublished

This text of Royal Borough of Kensington and Chelsea v. Tara Bafna-Louis (Royal Borough of Kensington and Chelsea v. Tara Bafna-Louis) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Royal Borough of Kensington and Chelsea v. Tara Bafna-Louis, (2d Cir. 2023).

Opinion

23-470 Royal Borough of Kensington and Chelsea v. Tara Bafna-Louis

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

1 At a stated term of the United States Court of Appeals for the Second Circuit, 2 held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the 3 City of New York, on the 22nd day of September, two thousand twenty-three. 4 5 PRESENT: REENA RAGGI, 6 RAYMOND J. LOHIER, JR., 7 SUSAN L. CARNEY, 8 Circuit Judges. 9 ------------------------------------------------------------------ 10 ROYAL BOROUGH OF 11 KENSINGTON AND CHELSEA, 12 13 Petitioner-Appellee, 14 15 v. No. 23-470 16 17 TARA BAFNA-LOUIS, ALSO 18 KNOWN AS TALIA BECKER, 19 TALIA LOUIS, TARA BECKER, 20 TARA MAYNARD, TALIYA 21 BECKER, AND/OR TALIYA LOUIS, 22

1 1 Respondent-Appellant. 2 ------------------------------------------------------------------ 3 4 FOR PETITIONER-APPELLEE: KELLY ANN POWERS, Stephen 5 John Cullen, Miles & 6 Stockbridge P.C., Washington, 7 DC

8 FOR RESPONDENT-APPELLANT: VALDI LICUL, Wigdor LLP, 9 New York, NY

10 Appeal from an order of the United States District Court for the Southern

11 District of New York (P. Kevin Castel, Judge).

12 UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

13 AND DECREED that the order of the District Court is AFFIRMED.

14 Respondent-Appellant Tara Bafna-Louis appeals from an order of the

15 United States District Court for the Southern District of New York (Castel, J.)

16 requiring the return of her child, Baby L, to the United Kingdom pursuant to the

17 Hague Convention on the Civil Aspects of International Child Abduction, Oct.

18 25, 1980 T.I.A.S. No. 11,670, 1343 U.N.T.S. 89, reprinted in 51 Fed. Reg. 10,494

19 (Mar. 26, 1986) (“Hague Convention” or “Convention”) and its implementing

20 statute, the International Child Abduction Remedies Act, 22 U.S.C. § 9001

21 (“ICARA”). We assume the parties’ familiarity with the underlying facts and the

2 1 record of prior proceedings, to which we refer only as necessary to explain our

2 decision to affirm.

3 The Convention seeks “to secure the prompt return of children wrongfully

4 removed to or retained in any Contracting State,” and “to ensure that rights of

5 custody and of access under the law of one Contracting State are effectively

6 respected in the other Contracting States.” Abbott v. Abbott, 560 U.S. 1, 8 (2010)

7 (quoting Hague Convention, Art. 1). “The United States is a Contracting State to

8 the [C]onvention.” Hofmann v. Sender, 716 F.3d 282, 290 (2d Cir. 2013). “[T]o

9 prevail on a claim under the [] Convention a petitioner must show that (1) the

10 child was habitually resident in one State and has been removed to or retained in

11 a different State; (2) the removal or retention was in breach of the petitioner’s

12 custody rights under the law of the State of habitual residence; and (3) the

13 petitioner was exercising those rights at the time of the removal or retention.”

14 Gitter v. Gitter, 396 F.3d 124, 130–31 (2d Cir. 2005). A respondent who opposes a

15 child’s return may establish certain defenses under Article 13 of the Convention.

16 See Souratgar v. Lee, 720 F.3d 96, 103 (2d Cir. 2013). In cases arising under the

17 Convention and ICARA, we review a district court’s factual findings for clear

18 error and its legal conclusions de novo. Ozaltin v. Ozaltin, 708 F.3d 355, 368 (2d

3 1 Cir. 2013). “Legal conclusions include interpretations of the Convention and

2 applications of the appropriate legal standards to the facts.” Id.

3 I. Habitual Residence

4 Bafna-Louis first challenges the District Court’s determination that Baby

5 L’s habitual residence is the United Kingdom. A child’s habitual residence

6 presents a “mixed question of law and fact—albeit barely so.” Monasky v.

7 Taglieri, 140 S. Ct. 719, 730 (2020) (quotation marks omitted). “Once “the trial

8 court correctly identifies the governing totality-of-the-circumstances standard,

9 however, what remains for the court to do in applying that standard . . . is to

10 answer a factual question: Was the child at home in the particular country at

11 issue?” Id. Because the District Court here identified the correct legal standard,

12 we review its habitual residence determination “by a clear-error review standard

13 deferential to the factfinding court,” id., keeping in mind that “courts must be

14 sensitive to the unique circumstances of the case and informed by common

15 sense,” id. at 727 (quotation marks omitted).

16 In general, “[a] child ‘resides’ where she lives. [A child’s] residence in a

17 particular country can be deemed ‘habitual,’ however, only when her residence

18 there is more than transitory.” Id. at 726 (citations omitted). For children who

4 1 are too young to acclimate to their surroundings — as is the case with Baby L —

2 the “intentions and circumstances of caregiving parents are relevant

3 considerations.” Id. at 727. “No single fact, however, is dispositive[.]” Id.

4 Here, the District Court considered all of the relevant factors and credited

5 Bafna-Louis’s testimony that she intended to relocate to New York with Baby L.

6 The District Court nevertheless found that Baby L was a habitual resident of the

7 United Kingdom. That finding was supported principally by the following

8 record evidence: (1) Baby L was born in London and was issued a passport by

9 the United Kingdom; (2) at the time Baby L was born, Bafna-Louis “had long

10 maintained a residence in [the United Kingdom];” (3) when Bafna-Louis traveled

11 internationally prior to Baby L’s birth, she resided principally in the United

12 Kingdom; and (4) Baby L’s biological father was physically located in the United

13 Kingdom, and the court proceedings related to him occurred there. Royal

14 Borough of Kensington & Chelsea v. Bafna-Louis, No. 22-CV-8303 (PKC), 2023 WL

15 2387385, at *13–14 (S.D.N.Y. Mar. 7, 2023). On such a record, we cannot conclude

16 that the District Court clearly erred in finding that Baby L’s habitual residence is

17 the United Kingdom.

5 1 II. Custody Rights

2 Bafna-Louis next challenges the District Court’s conclusion that the Royal

3 Borough of Kensington and Chelsea (“RBKC”) had custody rights over Baby L at

4 the time Baby L was removed from the United Kingdom. Article 3 of the

5 Convention states, in relevant part, that the removal of a child is wrongful where

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Abbott v. Abbott
560 U.S. 1 (Supreme Court, 2010)
Felix Blondin v. Marthe Dubois
189 F.3d 240 (Second Circuit, 1999)
Ozaltin v. Ozaltin
708 F.3d 355 (Second Circuit, 2013)
Hofmann v. Sender
716 F.3d 282 (Second Circuit, 2013)
Souratgar v. Fair
720 F.3d 96 (Second Circuit, 2013)
Monasky v. Taglieri
589 U.S. 68 (Supreme Court, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Royal Borough of Kensington and Chelsea v. Tara Bafna-Louis, Counsel Stack Legal Research, https://law.counselstack.com/opinion/royal-borough-of-kensington-and-chelsea-v-tara-bafna-louis-ca2-2023.