On December 4, 2013, the Supreme Court of the United Kingdom unanimously ruled in In the Matter of KL (A Child) that UK courts have inherent jurisdiction to order the return of a child.  The case concerned a child, K, who had been born in Texas to an American father and a Ghanaian mother with indefinite leave to remain in the UK.  After the parents divorced and K was taken to the UK with his mother pursuant to U.S. federal district court order, the U.S. Court of Appeals for the Fifth Circuit reversed and the lower court later ordered K’s return to the United States.  The father’s subsequent applications under the Convention were dismissed by both the UK’s High Court and Court of Appeal.  According the Supreme Court, “[u]nder the Family Law Act 1986, the High Court has power to exercise its inherent jurisdiction in relation to children by virtue of the child’s habitual residence and presence here.”  The Court thus allowed the father’s appeal and ordered the return of K to the United States “on the basis of the undertakings offered by [K’s] father.”