Filed December 30, 2016
“Under ICARA, federal district courts have concurrent jurisdiction with state courts to determine ‘rights under the Convention [but] not the merits of any underlying child custody claims.’ 42 U.S.C. § 11601(b)(4), 11603(a).” McKie v. Jude, 2011 WL 53058, at *4 (E.D. Ky. Jan.