Part 2: Legal Framework – Parental Rights and Third-Party Limitations

By Lynne Marie Kohm © 2026

In Part 1, we examined the deeply personal circumstances surrounding C. S. Lewis’ unexpected role as stepfather to the Gresham boys, drawing on his correspondence to reveal both the emotional and practical challenges he faced as their mother’s health declined. Those letters offer a compelling narrative — but they also raise a critical question: what does the law require in such circumstances? To answer that question, Part 2 turns to the governing legal principles that define parental rights, limit stepparent claims, and shape the custody outcomes that follow the death of a custodial parent. 

“I shall of course be obliged to place every legal obstacle in your way”

The issue presented in this essay is whether, when, and how does a stepparent of just a few short years stabilize a broken family to protect the best interests of the children while his new wife, who has custody of the children, is dying?

Considering how C. S. Lewis handled the care of his wife’s sons in the shadow of her imminent demise provides a template for every stepparent, and even for every surviving natural parent, going forward after the death of a custodial parent.

“[T]he boys remember you as…”

The facts surrounding the custody of David and Douglas Gresham, C.S Lewis’ stepsons, are extremely important for this inquiry. Helen Joy Davidman (Joy) married William Lindsay Gresham (Bill) on August 24, 1942.[1]  Together they had two children, David and Douglas.[2] During their tumultuous marriage, the children endured a level of abuse from their father which included dramatic physical and emotional abuse as detailed later: “The boys remember you as a man who fired rifles thro’ ceilings to relieve his temper, broke up chairs, wept in public, and broke a bottle over Douglas’s head.”[3]

In 1952 Joy had taken a trip to the U. K. to meet C. S. Lewis, with whom she had been corresponding regarding her faith and his writings.[4] During this time she wrote letters home to Bill and the boys about her tourism in the U.K.,[5] and to others about her friendship with C. S. Lewis (Jack).[6]

Joy and Bill struggled emotionally and financially,[7] and separated for a period, at which time Bill’s paramour (and Joy’s cousin), Renee, moved into the family home.[8] “David knew, and resented, the fact that you were living with your present wife while still married to his mother.”[9] With this change of family circumstances, Joy wrote to Bill with some urgency that the “boys do come first with me and no power on earth will ever separate me from them again.”[10]

Joy and Bill were divorced in 1954 before the boys reached their teen-age years.[11] The divorce originally filed in New York on June 1, 1953 was finalized in Florida on July 28, 1954, awarding Joy “the permanent custody and control of the minor children.”[12] Bill was awarded the “right of visitation at all reasonable times and places.”[13] Bill married Renee on the same date of the divorce decree.[14]

During this period Joy was also pursuing U.K. citizenship. Having arrived in the country on November 13, 1953, she applied for her Certificate of Immigration on October 2, 1954, obtaining a visa to stay in the country until November 13, 1955,[15] which was later extended to May 31, 1956.[16] At some point during this time Joy shared with Jack her potential deportation as her visa was about to expire.[17] Before that happened Joy and Jack were married by civil ceremony in a register office on April 23, 1956.[18] Her immigration deportation conditions were then cancelled.[19] While this apparent marriage of convenience allowed for Joy’s legal residence in the U.K., Jack and Joy remarried in a religious ceremony on March 21, 1957 at her hospital bedside upon her receipt of her medical diagnosis of terminal cancer.[20] Instead of dying, Joy’s cancer went into remission, allowing her and the boys to move back to the Lewis family home commonly referred to as the Kilns.[21]

Bill, however, wanted to come to the U. K. to retrieve his sons and return them to their home in New York.[22] Jack subsequently wrote his letter of June 4, 1957, asking Bill to “wait,” to reconsider what it would do to the boys to leave their mother at such a time, forcing them to return to the U.S. against their will.[23] Jack followed his own letter with a reply to Bill’s letter to Joy on his retaking custody of the boys, laying out what each thought was best for the boys during their mother’s illness.[24]

Joy had executed her Last Will and Testament on October 24, 1956, appointing Jack as the executor of her estate as well as guardian for the boys.[25] Joy also filed for citizenship for the boys on April 15, 1957, and they were subsequently seen and interviewed by Oxford Police.[26] The boys later took their Oath of Allegiance on August 24, 1957, receiving full legal immigration status.[27] The family enjoyed life together at the Kilns for the next three years, with the boys adjusting to their appropriate schools and friends.[28]

Though in remission during this time, Joy’s cancer returned, and she succumbed to death on July 13, 1960.[29] Bill had planned to visit the boys in Oxford later in July, but Joy’s death prompted Jack to send off a short missive on July 15, 1960 informing Bill of her death, noting “This need involve no change in your plans, but I thought you should arrive knowing it.”[30] Jack had “accepted responsibility for” the boys.[31]

Bill did visit the boys and Jack at the Kilns in Oxford, and was apparently convinced that they were well-cared for under these circumstances, as evidenced by the fact that he returned to America without them.[32] His letter to his brother, Hank, the boys’ closest uncle, reveals a somewhat settled sense of peace for all the parties involved.[33]

“What is certain is that a good deal of your money and mine will go into the lawyers’ hands.” 

The legal rules surrounding parental rights, custody in general, and the law on third party rights in any question of custody or visitation deserve a full vetting here to understand the challenges facing stepparents generally, and C.S. Lewis particularly. What are parental rights and where do they come from? And how are parents held responsible for how each handles a child’s best interests? These questions must be answered by setting out the legal rules surrounding the custody of any child.

It is a well-established constitutional principle protected as fundamental that parents have the right to direct the upbringing of their children.[34] Those parental rights are guaranteed until the parent has been shown to be unfit by clear and convincing evidence of abuse, neglect or abandonment,[35] and his or her parental rights have been terminated.[36]  Indeed, a fit parent is presumed to be acting in the best interests of his child.[37] Any such termination of parental rights is by design very challenging to accomplish in such a constitutionally protected context.[38]

This constitutional protection of parental rights, however, is balanced by the parental duty to provide for their children, and as the lawful guardians of their children are entitled to protect, train, direct, and speak for their children.[39] While these constitutionally protected parental rights are not absolute,[40] parental rights were “derived from. . . their duty; this authority being given them, partly to enable the parent more effectually to perform his duty, and partly as a recompense for his care and trouble in the faithful discharge of it.”[41]

And while the Constitution of the United States does not explicitly mention parents’ rights, nevertheless, American courts have long recognized that parents are entitled to very broad latitude in raising their children.[42] The High Court has clearly stated that “[t]he liberty interest at issue []—the interest of parents in the care, custody, and control of their children—is perhaps the oldest of the fundamental liberty interests recognized by this Court,”[43] emphasizing heavily the presumption of the parent’s “fundamental right to make decisions concerning the care, custody, and control of her [children],” thus preceding any discussion or analysis of the best interests of the child.[44] That means that any analysis of what is best for the children comes only after a determination that the parental rights are primary.

The logical conclusion of this is that protection of parental rights is the first line of defense for a child’s best interests, and the last line of resistance and protection against government control of children and families.[45] Parental rights protections serve children’s best interests. Because family law encompasses local domestic relations laws, the fifty states have established their own standards for determining a child’s best interests.[46] “Although there is no standard definition of ‘best interests of the child,’ the term generally refers to the deliberation that courts undertake when deciding what type of services, actions, and orders will best serve a child as well as who is best suited to take care of a child.”[47] The overarching objectives for a child’s best interests are stability and continuity for the child, and these goals generally reveal themselves in an analysis of factors that include aspects of a child’s life such as emotional ties, relationships between the children and their caregivers, the capacity of parents to provide safe and adequate needs of the child, the mental and physical health of the child, and of the parents, as well as the presence of any domestic violence in the home.[48] These factors are applied as to the natural or adoptive parents.

So while parental rights are fundamental and constitutionally protected, they are not without limits as noted, and when a natural custodial parent dies, the surviving parent by law generally resumes his or her parenting in retaking custody of the children.[49] “Therefore, a fit surviving parent will generally regain custody of his or her child in the event of the death of the custodial natural parent.”[50] And if a child’s parents are divorced, “the prevailing rule is that the divorce decree abates upon the death of one of the parties, and the custody of the children automatically passes to the surviving parent.”[51] If the parents were never married, a child’s surviving biological parent would also benefit from this presumption.[52] Custody will usually be granted to the surviving natural parent, unless the court finds his or her parental rights have been terminated.[53] Therefore, when a married parent of minor children dies, the surviving parent, rather than any stepparent, shall be presumed the custodian without court interference based on this presumption.[54]

This right belongs only to parents and not to relatives, stepparents, godparents, or any type of psychological parent,[55] though individuals of such standing may indeed petition for custody or visitation under appropriate circumstances.[56] The surviving parent, even if divorced or estranged from the deceased parent, is generally the person favored to take guardianship of the child,[57] and can ostensibly do so without court interference based on this parental presumption.[58]  When parents are divorced, the non-custodial parent may need to obtain a court order for the custody of his or her children, unless a shared custody order is already in place.[59] It is quite apparent that a stepparent seeking to continue to care for the children in his household faces many challenges when the children’s mother dies.

There are, nevertheless, additional circumstances and legal rules to establish and protect the opportunities and rights of third parties in some ways that pertain to protecting the best interests of children involved. Third party parents are any who are not natural or adoptive parents, and may sometimes also be termed as de facto, psychological, or virtual parents, and stepparents fall into this category.[60] The rules surrounding stepparents, and other third parties seeking visitation or custody of any child from a natural parent, are not favorable to them at the outset, as they generally have no legal rights until a natural parent loses his or her parental rights, and the stepparent can thereafter pursue adoption of the children.[61] In order for a stepparent to win custody of a child from a natural parent unique circumstances are required to cause any court to rule against fundamental constitutional protections that natural parents enjoy.[62]

Another consideration is that legal authority matters. Jurisdiction of any claim for a child’s custody can be based on either the original jurisdiction of the custody decree, or on the residence of the child.[63] Applying these rules to the Gresham boys, the original custody assignment was set forth in the Florida divorce decree.[64] The children, however, had been living in England with their step father for the three years during the time of their mother’s marriage to Lewis, from 1957 until her death in 1960.[65] A brief custody analysis places the children’s best opportunities for stability and continuity where they were then residing at the Kilns, but a natural parent could make a very strong argument for return of the children to the residence of the surviving natural parent, based on parental rights claims and original jurisdiction of the custody matter.[66]

Closing

The governing legal principles make plain that, however devoted a stepparent may be, the law begins with a strong presumption in favor of the surviving natural parent. This framework, grounded in constitutional protections, presents significant challenges to any stepparent seeking to preserve stability for the children in his or her care. Yet within these constraints there remains room for thoughtful action; in Part 3, we will examine how C. S. Lewis navigated these realities and what practical guidance his example offers.

[1] Both were writers, William Lindsey Gresham’s most famous work was Nightmare Alley (1946), and Joy Davidman’s most famous work was Smoke on the Mountain: An Interpretation of the Ten Commandments (1953).

[2] Hooper, supra note 8, at 696.

[3] Letter to William Gresham, dated April 6, 1957, in Letters, Vol. III, supra note 13, at 843.

[4] Joy Davidman Papers, Collection Identifier A-109, Folder 6, Wade Center.

[5] Id.

[6] Id. Joy wrote in a letter to Lewis biographer, Chad Walsh, about her receiving a letter from Lewis regarding some points they had been arguing, stating “He knocked my props out from under me unerringly; one shot to a pigeon. I haven’t a scrap of my case left. And, what’s more, I’ve seldom enjoyed anything more.” Out of My Bone, The Letters of Joy Davidman 116, Don W. King, Ed (Wm. B. Eerdmans Pub. Co. 2009).

[7] Bill seemed to be always in poor financial position, as evidenced by the numerous correspondence between Bill and his attorneys that merely included pleas for payment. Gresham Papers, Folders A-51a, and 55, Wade Center.

[8] Id. See also Letters, Vol. III, supra note 13, at 1692 (noting when Joy’s cousin, Renee Pierce, brought her two children to stay in the Gresham home).

[9] Letter to William Gresham, dated April 4, 1957, in Letters, Vol. III, supra note 13, at 843.

[10] Letter dated Nov. 17, 1952, p. 2, Joy Davidman Papers, Collection Identifier A-109, Folder 7, Wade Center.

[11] Decree of Divorce, Dade County, FL, In Chancery, No. 169619-G, dated July 28, 1954; Joy Davidman Papers, 1926-1964, Folder 14, Wade Center. David was age 10 and Douglas was age 8. Id.

[12] In Chancery No. 169619-G, Dade County, FL (Jul. 28, 1954).

[13] Id. noting that visitation should take place “at the wife’s residence.”

[14] “Gresham and (Renee) Rodriquez married in 1954, on the same day his divorce from Davidman was finalized.” G. Connor Salter, Remembering William Lindsey Gresham: Interview with Rosemary Simmons, Fellowship & Fairydust, Nov. 22, 2022, https://fellowdustmag.com/2022/11/22/remembering-william-lindsay-gresham-interview-with-rosemary-simmons/#_ftn1. Rosemary Simmons was Renee’s daughter. Id.

[15] Joy Davidman Papers, Folder 14, Wade Center.

[16] This extension was apparently given following her request based on domestic violence at home in the U.S. See Joy Davidman Papers, Folders 13b, 14, 18 Wade Center. (verify these are the correct folders and citations)

[17] Id.

[18] Hooper, supra note 8, at 697. See certified copies of the aforementioned Divorce Certificate, Marriage Certificate, and Immigration Certification, in Joy Davidman Papers, Folder 14, Wade Center. “They were married in the register office in St Giles, Oxford, on 23 April 1956” but when Joy was thought to be dying of cancer, “on 21 March 1957 Lewis and Joy were married in the Wingfield-Morris Hospital by the Rev. Peter Bide… Joy was moved to the Kilns in 2 April 1957…” Letters, Vol. 3, at 1693.

[19] Joy Davidman Papers, Folder 14, Wade Center.

[20] A great deal has been discussed about these marital circumstances, much of which is contained in the 1993 British biographical film by Richard Attenborough, Shadowlands.

[21] Joy Davidman Papers, Folder 14, Wade Center. All thought she was going home to die. See Lewis Letter to Sister Penelope, Hooper, supra note 8, at 85. 

[22] This intention is indicated from the content of Lewis’ letter to Bill on Joy’s behalf in response to Bill’s letter to Joy. See letters to William Gresham, Apr. 6, 1957, in response to Bill’s request for the custody of the boys to Joy, in Letters, Vol. III, supra note 12, at 843-44.

[23] Letter to William Gresham, April 6, 1957, in Letters, Vol. III, supra note 12, at 843-44.

[24] See letters to William Gresham, Apr. 6, 1957, in response to Bill’s request for the custody of the boys to Joy, in Letters, Vol. III, supra note 12, at 843-44.

[25] Last Will and Testament of Joy Davidman, dated Oct. 24, 1956, also in Joy Davidman Papers, Folder 14, Wade Center. Additional terms not relevant to this inquiry are noted in her Codicil dated Oct. 3, 1959. Id.

[26] Joy Davidman Papers, Folder 14, Wade Center.

[27] Id. Lewis’ friend and attorney, Owen Barfield, provided the necessary legal guidance. Id. His foresight, guidance, drafting, and direction likely made a great deal of difference in this family’s outcomes.

[28] See generally Douglas Gresham, Lenten Lands: My Childhood with Joy Davidman & C.S. Lewis (Macmillan 1988).

[29] Hooper, supra note 8, at 99.

[30] Letter to William Gresham, July 15, 1960, in Letters, Vol. III, supra note 13, at 843-44.

[31] Notes following Letter to Mary Willis, July 15, 1960, in Letters, Vol. III, supra note 13, at 1171-72:

               David and Douglas returned to school after their mother’s death. Lewis accepted responsibility for them, but he was fortunate in having the help of Joy’s friend, Jean Wakeman. The boys knew her well by this time, and she made it clear that they could always regard her hours, a few miles away at Horton-cum-Studley, as their home.”

Id. at 1172.

[32] The Kilns remained the boys’ residence throughout the remainder of their childhood, never visiting the U.S. again during that time. Gresham, Lenten Lands, supra note 41.

[33] Letter from William Gresham to Hank, dated Sep. 11, 1960 (on file with the Gresham Papers, Collection ID A-86-91, Folder 61, Marion E. Wade Center, Wheaton College, Wheaton, IL). Bill’s visit with the boys and Jack at the Kilns after Joy’s death is also discussed by Van Maren, supra note 11 (hailing Bill as “a veteran of the Spanish Civil War and an accomplished writer in his own right”), also noting Bill’s demise. “In the U.S. shortly thereafter, William killed himself after being diagnosed with tongue cancer.” Id.

[34] See Meyer v. Nebraska, 262 U.S. 390 (1923)(holding unconstitutional a Nebraska law that prevented parents from allowing their children to learn German despite the state’s policy otherwise); Pierce v. Society of Sisters, 268 U.S. 510 (1925)(holding that parental choice of an appropriate education for their children is a constitutional right and liberty interest under the constitution); Troxel v. Granville, 530 U.S. 57 (2000)(holding that state law cannot grant visitation to any third party against a fit parent’s objection).

[35] See Santosky v. Kramer, 455 U.S. 745 (1982)(first setting out that standard, holding that “[b]efore a State may sever completely and irrevocably the rights of parents in their natural child, due process requires that the State support its allegations by at least clear and convincing evidence.”).

[36] See Termination of Parental Rights, Child Welfare Information Gateway (2016), https://www.childwelfare.gov/topics/systemwide/courts/processes/legal-issues-in-adoption/termination/. Family reunification is the state’s persevering objective, and termination of parental rights is a remedy of last resort. Therefore a parent’s fundamental right to direct the upbringing of their children will be restricted rather than revoked in any matter of custody of visitation.  Termination of parental rights is, therefore, a last resort to protect the children. Id.

[37] Troxel v. Granville, 530 U.S. 57, 68 (2000).

[38] See, e.g. John Thomas Halloran, Families First: Reframing Parental Rights as Familial Rights in Termination of Parental Rights Proceedings, 18 UC Davis J. Juv. L. & Pol’y 51 (2014) (examining the challenges of severing the parent-child relationship).

[39] Troxel, at 69. See also generally Lynne Marie Kohm, Tracing the Foundations of the Best Interests of the Child Standard in American Jurisprudence, 10 J. L. Fam. Stud. 337, 354, 359 (2008). The guardianship relationship is grounded in the reality that children are born completely incompetent and dependent, and mature in a slow process over the course of many years. Id.

[40] See Prince v. Massachusetts, 321 U.S. 158 (1944) (curtailing those rights by prohibiting child labor).

[41] William Blackstone, Commentaries on the Laws of England Book 1, Ch. 16: Of Parent and Child 447 (1776-69) also available at https://avalon.law.yale.edu/18th_century/blackstone_bk1ch16.asp.

[42] Troxel, 530 U.S. 57 (2000).

[43] Id. at 65. 

[44] Id. at 68, 72. For a comprehensive review of how case law has affected, established, and molded a new order of family law see David Wagner, The Family and American Constitutional Law, 1 Life, Liberty & Fam. 145 (1994).

[45] See generally Kohm, Tracing, supra note 56.

[46] Id.

[47] Determining the Best Interests of the Child, Child Welfare Information Gateway, Nov. 2022, childwelfare.gov, https://www.govinfo.gov/content/pkg/GOVPUB-HE23_1200-PURL-gpo88013/pdf/GOVPUB-HE23_1200-PURL-gpo88013.pdf. “’Best interests’ determinations are generally made by considering a number of factors related to the child’s circumstances and the parent or caregiver’s circumstances and capacity to parent, with the child’s ultimate safety and well-being the paramount concern.” Id.

[48] Id. (also detailing the numerous factors of the several states and how they vary).

[49] See generally Kohm, supra note 2 (examining the problem of guardianship in the event of the death of the custodial parent).

[50] Id. at 4.

[51] Wilks, supra note 1, at 124.

[52] See UNIF. PARENTAGE ACT § 202 cmt. (2002) (stating that the provision reaffirms “the principle that regardless of marital status of the parents, children and parents have equal rights with respect to each other.”).

[53] See id. at § 203 (stating that “[u]nless parental rights are terminated, a parent-child relationship established under this [Act] applies for all purposes, except as otherwise specifically provided by other law of this State.”).

[54] Kohm, supra note 56, at 5.

[55] A psychological parent is a person who is not necessarily biologically related to the child, but someone who a child “regards as a parent… fulfill[ing] the child’s emotional and physical needs consistently. A psychological parent can be a biological parent, foster parent, guardian, common-law parent, or any other person who plays a significant role in the child’s upbringing. Sometimes, this role is referred to as a ‘de facto’ parent.” What is a Psychological Parent? U.S. Legal (2026), https://legal-resources.uslegalforms.com/p/psychological-parent. Legal recognition of psychological parents varies by state. For example, Oregon recognizes the psychological parent by statute at ORS 109.119; while Virginia specially refuses to recognize the concept, and rather uses the “person of legitimate interest” standard instead. Va. Code§ 20-124.1.

[56] Id. States vary in their application of who can petition for custody of a child in the wake of the custodial parent’s death. For example, Virginia uses the person of legitimate interest hierarchy to consider who may assert rights and responsibilities of the children in any third party custody claim. Va. Code § 20-124.1 (2024). Tennessee uses a clear best interests analysis under Tenn. Code § 36-6-106, outlining how custody decisions should be made based on the best interests of the child, including provisions for the situation where a custodial parent has died; noting that a surviving biological parent generally retains custody unless there are compelling reasons otherwise, and if the deceased custodial parent has named a legal guardian in their will that guardian may be appointed depending on the circumstances. Tenn. Code § 36-6-106.

[57] Id. Additionally, he or she is generally the person favored to gain control over the child’s inheritance in the event that a trustee is not appointed. Douglas E. Abrams, Sarah H. Ramsey, & Susan Vivian Mangold, Children and the Law in a Nutshell 382 (5th ed. 2015) (stating that “[i]n the absence of a contrary determination, parents are naturally the guardians of the person of the child, and thus are also a logical choice to manage the child’s property.”). This can be extremely important, and even (dare it be mentioned) incentivizing to a guardian to assert these rights; again, any court will emphasize an analysis based on what is best for the children, rather than what is best for the adults. See discussion infra note 121 as applied to the Gresham boys.

[58] Kohm, supra note 56.

[59] The majority rule is set out in Wilks, supra note 1.

In line with the minority approach, it has been held that the death of the parental custodian does not affect the power of the court of equity that has assumed jurisdiction over the custody of the children. The children become wards of the court by virtue of the [divorce] decree, and no one succeeds to the right of custody of the children because of the death of the parental custodian. His death merely serves to require the court to make other provisions for the custody of the children.

Id. at 127.

[60] See e.g. Christina Spiezia, In the courts: state views on the psychological-parent and de facto-parent doctrines, 33 Child. Legal Rts. J. 401 (2013); and Solangel Maldonado, De facto parents, legal parents, and inchoate rights, 91 U. Chi. L. Rev. 557 (2024), each explaining and detailing the status of these third parties seeking parental rights. Grandparents also fall into this category of third party non-parents. See generally Troxel, 530 U.S. 57.

[61] The step parent can gain custodial rights generally only by judicial petition for adoption.

“An uncontested stepparent adoption generally gives the law’s imprimatur to an existing family structure. Where the surviving stepparent wishes to adopt his deceased spouse’s child, the best-interests-of-the-child standard would determine the outcome. If no competing petition is filed, the court would likely approve the adoption unless the stepparent appears unfit. If a close relative also petitions to adopt the child, however, the stepparent may lose because the stepparent (like the close relative) is a legal stranger to the child.”

Abrams, supra note 74, at 263-64.

[62] A great deal of literature is available on the challenges facing step parents. See, e.g., Kay Pasley and Brad S. Moorefield, Chapter 18, Step Families: Changes and Challenges, in Handbook of Contemporary Families (Sage 2004); Madeline Beaudry, Jean-Marie Boisvert, Marie C. Simard, and Claudine Parent, Communication: A key component to meeting the challenges of stepfamilies, 42 J. Divorce & Remarriage (Taylor & Francis 2024); Annie Pakarinen and Laura Selanne, Perceived Stepfamily Challenges: A Cross-Sectional Descriptive Study Among Stepfamilies and Social and Health Care, 16 Int’l. J. Child, Youth and Fam. (2025).

[63] A form of the Uniform Child Custody Jurisdiction Act (UCCJA) has been adopted by each of the fifty states, and sets forth these factors as primary guidance. See also Lynne Marie Kohm, Examining Jurisdictional Child Protections in Gender Dysphoria Contexts, 3 Pro Tempore 1 (2023) (explaining the challenges of custody litigation across jurisdictional lines). Here regarding the Gresham brothers, custody litigation would have been even more complicated as it would be across international boundaries. For an analysis of international custody considerations see Kathleen A. McKee, A Primer on International Parental Abduction, 6 Regent J. Int’l L. 37 (2008) (setting forth the workings of the Hague Convention in child custody claims between signatory nations of the Hague Convention, of which both the U.S. and the U.K. are signatories). Fortunately, all litigation was averted.

[64] Decree of Divorce, Dade County, FL, In Chancery, No. 169619-G, dated July 28, 1954.

[65] Hooper, supra note 8, at 85, 99.

[66] That is likely exactly what Bill intended to do before he visited the boys and Jack at The Kilns (see infra notes 122-23), but we may never know, as Bill never made any such claim.