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Matter of Naamye Nyarko B. v. Goodwin Edwin C.

Citation: 2021 NY Slip Op 05453Docket: Docket No. V34239-14/17C V34240-14/17C V04388/17/17A/17B V04389/17/17A/17B Appeal No. 14329 Case No. 2019-3138

Court: Appellate Division of the Supreme Court of the State of New York; October 12, 2021; New York; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In the case of Naamye Nyarko B. v. Goodwin Edwin C., the Appellate Division of the New York Supreme Court reversed a Family Court order that allowed the respondent father to travel internationally with the children on 60 days' written notice to the petitioner mother. The court found that the Family Court erred in modifying the custody and visitation order to permit unrestricted international travel, particularly to Ghana, which is not a signatory to the Hague Convention on Civil Aspects of International Child Abduction. The Appellate Division determined that there was no substantial basis in the record to support the conclusion that such unrestricted travel was in the best interests of the children. The decision was entered on October 12, 2021, and was made by Justices Renwick, Kern, Oing, Mendez, and Rodriguez. The appeal was represented by the Law Offices of Randall S. Carmel for the appellant, Bruce A. Young for the respondent, and Andrew J. Baer as the attorney for the children.

Legal Issues Addressed

Best Interests of the Child

Application: The Appellate Division determined that permitting unrestricted international travel was not in the best interests of the children, due to lack of substantial basis in the record.

Reasoning: The Appellate Division determined that there was no substantial basis in the record to support the conclusion that such unrestricted travel was in the best interests of the children.

International Child Abduction Concerns

Application: The court noted the significance of the destination country's status regarding the Hague Convention, impacting the decision on international travel permissions.

Reasoning: The court found that the Family Court erred in modifying the custody and visitation order to permit unrestricted international travel, particularly to Ghana, which is not a signatory to the Hague Convention on Civil Aspects of International Child Abduction.

Modification of Custody and Visitation Orders

Application: The court reversed a Family Court order that allowed the respondent father to travel internationally with the children, finding that the modification was not supported by the record.

Reasoning: The court found that the Family Court erred in modifying the custody and visitation order to permit unrestricted international travel, particularly to Ghana, which is not a signatory to the Hague Convention on Civil Aspects of International Child Abduction.