Sixth Circuit: Liz Lopez Moreno v. Jason Zank

When a parent allegedly wrongfully removes a child from a country after the allegedly wrongful removal of the child to that country by the other parent, given the purposes of the Convention, the first parent is precluded from asserting that the residence of the child in the country to which it had been removed at first was not their habitual residence; to preserve future claims under the Convention, the Convention  remedy must be invoked, as opposed to self-help.

http://www.opn.ca6.uscourts.gov/opinions.pdf/18a0147p-06.pdf