Coe v. Coe, Record No. 0854–15–4, decided on July 26 2016, adopts the U.S. Court of Appeals Fourth Circuit definition of habitual residence for purposes of the Hague Convention on Civil Aspects of International Child Abduction. Habitual residence is not defined in the Hague Convention, but in Virginia it now consists of the place where a child has been “physically present for an amount of time sufficient for acclimatization and which has a degree of settled purpose from the child’s perspective.” Most remarkable about this opinion is not its adoption of a widely-respected definition of “habitual residence”; but the fact that appellant’s case was so weak, and his counsel was so heavily criticized by the appellate court. Briefly, here are the facts: Daughter was born in 2007. The parties lived in Arizona until 2011 when mother moved to her native Korea with daughter and father went to Afghanistan. Later that year, they vacationed in Phuket, Thailand. Father obtained an Arizona divorced in 2012, and returned to the States in 2014 taking up residence in Virginia. At the end of 2014, father sent mother and daughter plane tickets to visit him from Korea. Immediately when they arrived, father hid their passports […] 5