On March 5, 2014, the United States Supreme Court in Lozano v. Montoya Alvarez unanimously ruled [3] 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.”