The Hague Convention on the Civil Aspects of
International Child Abduction generally requires that
children wrongfully removed or retained from their
country of habitual residence be returned promptly so
that custody disputes may be adjudicated in the
requesting country. Article 13 b of the Convention
provides an exception to that requirement when there
is a grave risk that returning the child would expose
the child to physical or psychological harm or place the
child in an intolerable situation.

The questions presented are:

1. After finding that a return would expose the
child to grave risk, is a district court required to
consider ameliorative measures?

2. If a district court considers ameliorative
measures, which party has the burden to prove the
ameliorative measures?

Whether a district court is required to consider ameliorative measures after finding that a return would expose the child to grave risk