Puerto Rican Habeas Judgment Not Entitled to Full Faith and Credit Pursuant to PKPA

In the case of E.N. v. E.S., the Massachusetts Court of Appeals ruled that a habeas corpus judgment obtained by father in Puerto Rico awarding him custody of parties’ older child was not entitled to full faith and credit in Massachusetts under Parental Kidnapping Prevention Act (PKPA), as Puerto Rico was not child’s “home state” within six months preceding filing of habeas corpus petition as required by PKPA. The child had left Puerto Rico with the mother at a time when there was no outstanding order awarding custody to father or prohibiting the child’s removal, and, as such, Puerto Rico was no longer child’s home state and had not been within six months preceding filing of habeas corpus petition.