Davis v. Ewalefo
Annotate this CaseAs stipulated, a child custody decree gave Mother and Father joint legal custody of their minor son and awarded Mother primary physical custody. The decree granted Father unsupervised visitation but specified that visitation could not occur in Africa where Father lived and worked. The decree also included a provision that forbade either parent from traveling with the child outside the United States absent court order or both parents’ consent. A divided three-judge panel affirmed. The Supreme Court granted en banc reconsideration and affirmed in part and reversed in part, holding that, without specific findings to connect the child’s best interests to the restrictions imposed, the travel and visitation restrictions could not stand.
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