No Equitable Tolling For Parents That Abduct Children.

When a parent abducts a child and flees to another country, the Hague Convention requires that country to return the child immediately if the parent requests return of the child within one year.  In this case, the mother and child disappeared from the United Kingdom in 2008, and the father did not locate them in New York until 2010, when he filed his action for return of the child. The United States Supreme Court held no equitable tolling to the one-year statute of limitations. (Lozano v. Alvarez (U.S. Sup. Ct.; March 5, 2014.)134 S.Ct. 1224, [188 L.Ed.2d 200].)