In Gonzalez-Caballero v. Mena, 251 F.3d (9th Cir. (Ariz.) 2001) the mother, a citizen of Panama, filed petition for return of her child against child's father, an American citizen. The district court's conclusions of law and conclusions of international law are reviewed de novo. Its findings of fact are reviewed under the clearly erroneous standard.

An appellate court must accept the lower court's findings of fact unless the appellate court is left with the definite and firm conviction that a mistake has been committed.

The mother's right to return of her child under the ICARA was extinguished, where the mother had consented to the father's removal and retention of the parties' child from Panama to the United States, even though the mother subsequently changed her mind.