This Note contends that New Zealand should not be obliged to return Hilary to the jurisdiction of United States courts. This Note also contends that the ultimate disposition of custody and visitation rights should be the prerogative of the New Zealand court and that prior or pending United States orders should not necessarily be considered binding on that court.
Suzanne M. Dale, Little Hilary: Happy at Last? New Zealand's Family Court and the Matter of Hilary Foretich, 9 Penn St. Int'l L. Rev. 411 (1991).