O.G. v. A.B.

A.B. (Mother) appealed the trial court’s order, which awarded shared custody to her and o.G. (Father). The Superior Court vacated the order and remanded.


On appeal, Mother argued that Father would not permit Mother to renew the children’s Russian passports. The Superior Court remanded and directed the trial court to determine whether the restriction on the renewal of the children’s Russian passports would affect the children’s status as dual citizens of the United States and Russia. If such restriction would cause a loss of the children’s dual citizenship, the Court directed the trial court to allow the renewal of the children’s Russian passports while requiring additional safeguards to prohibit those passports from being used without prior court approval.

The Court also found that the trial court abused its discretion by entering the custody order without an adequate review of Father’s tenant, who had a history of criminal charges as well as a PFA against him. The Court directed the trial court to make a more detailed inquiry and finding concerning any risk to the children after it had provided counsel the opportunity to cross-examine the particular tenant. 

O.G.