6th Cir.

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Case Commentary: Salame v. Tescari, 29 F.4th 763 (6th Cir. 2022)

James D. Garbolino

February 17, 2023

Grave Risk | Domestic Violence | Effect of Asylum Grant | Zone of War or Famine | Inability of Local Courts to Fairly Adjudicate Custody Case

Case Commentary: Douglas v. Douglas, No. 21-1335, 2021 WL 4286555 (6th Cir. Sept. 21, 2021)

James D. Garbolino

November 17, 2022

Habitual Residence | Summary Dispositions

In this case, the Sixth Circuit reviewed an habitual residence finding, applying the totality of the circumstances.

Holding

Certification of Questions of State Law in the U.S. Courts of Appeals for the Third, Sixth, and Ninth Circuits (2010–2018)

Jason A. Cantone, Carly E. Giffin

June 3, 2020

This report evaluates the use of certified questions of state law between 2010 and 2018 in three U.S. circuit courts of appeal: the Ninth, Sixth, and Third Circuits. The data shows variation in the rate of certification and timing of certification events between the circuits.

Case Commentary Update: Taglieri v. Monasky, 907 F.3d 404 (6th Cir. 2018)

James D. Garbolino

March 23, 2020

Habitual Residence

Case Commentary: Moreno v. Zank, 895 F.3d 917 (6th Cir. 2018)

James D. Garbolino

November 16, 2018

Habitual Residence

Case Commentary: Taglieri v. Monasky, 907 F.3d 404 (6th Cir. 2018)

James D. Garbolino

November 16, 2018

Habitual Residence | Infants

Case Commentary: Ahmed v. Ahmed, 867 F.3d 682 (6th Cir. 2017)

James D. Garbolino

February 12, 2018

Habitual Residence | Especially Young Children | Infants

The Sixth Circuit expanded the habitual residence standard to allow consideration of shared parental intent in cases involving especially young children who lack sufficient capacity to acclimate to any residence.

Case Commentary: Pliego v. Hayes, 843 F.3d 226 (6th Cir. 2016)

James D. Garbolino

April 21, 2017

Intolerable Situation | Courts of Habitual Residence

This case addresses whether an “intolerable situation” under Article 13(b) includes the inability of the courts of the habitual residence to litigate child custody.

Facts

Case Commentry: Friedrich v. Friedrich (Friedrich I), 983 F.2d 1396 (6th Cir. 1993), & Friedrich v. Friedrich (Friedrich II), 78 F.3d 1060 (6th Cir. 1996)

James D. Garbolino

January 20, 2016

Habitual Residence | Rights of Custody | Grave Risk | Consent and Acquiescence

Circuit CJA Case-Budgeting Attorney Pilot Project Evaluation (2007–2009) Appendix

Margaret S. Williams

December 20, 2010

During the period January through April of 2007, a case-budgeting attorney (CBA) was hired in each of the Second, Sixth, and Ninth Circuits as part of the Case-Budgeting Attorney Pilot Project authorized by the Judicial

Federal Judicial Center

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6th Cir.

Case Commentary: Salame v. Tescari, 29 F.4th 763 (6th Cir. 2022)

Case Commentary: Douglas v. Douglas, No. 21-1335, 2021 WL 4286555 (6th Cir. Sept. 21, 2021)

Certification of Questions of State Law in the U.S. Courts of Appeals for the Third, Sixth, and Ninth Circuits (2010–2018)

Case Commentary Update: Taglieri v. Monasky, 907 F.3d 404 (6th Cir. 2018)

Case Commentary: Moreno v. Zank, 895 F.3d 917 (6th Cir. 2018)

Case Commentary: Taglieri v. Monasky, 907 F.3d 404 (6th Cir. 2018)

Case Commentary: Ahmed v. Ahmed, 867 F.3d 682 (6th Cir. 2017)

Case Commentary: Pliego v. Hayes, 843 F.3d 226 (6th Cir. 2016)

Case Commentry: Friedrich v. Friedrich (Friedrich I), 983 F.2d 1396 (6th Cir. 1993), & Friedrich v. Friedrich (Friedrich II), 78 F.3d 1060 (6th Cir. 1996)

Circuit CJA Case-Budgeting Attorney Pilot Project Evaluation (2007–2009) Appendix

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