On March 5, 2014, the United States Supreme Court in Lozano v. Montoya Alvarez unanimously ruled that the equitable tolling doctrine does not apply to Article 12 of the Hague Convention on the Civil Aspects of International Child Abduction.  Under Article 12, when a parent abducts a child and flees to another country, that country must return the child immediately if the other parent requests return within one year.  Equitable tolling is a federal legal doctrine which “pauses the running of . . . a statute of limitations when a litigant has pursued his rights diligently but some extraordinary circumstance prevents him from bringing a timely action.  In making its decision, the Court reasoned that “the parties to the Hague Convention did not intend equitable tolling to apply to the 1-year period,” and that “the Convention was not adopted against a shared background of equitable tolling.”  Justice Alito, joined by Justice Breyer and Justice Sotomayor, wrote a concurring opinion in which he reasoned that “courts have equitable discretion under the Hague Convention to order a child’s return even after the child has become settled.”