In re Walsh, 31 F.Supp.2d 200 (D. Mass. 1998), the District Court, held that the evidence did not establish that return of children would expose children to grave threat of physical or psychological harm, and the father was entitled to return of the children the mother had abducted.

Evidence that the foreign father was intemperate and often unkind to the children, that he spanked them for minor infractions, and exposed them to verbal and physical conflict within the home, and that the daughter suffered from anxiety and stress related conditions was insufficient to establish that the return of the children to the father would expose children them to a grave threat of physical or psychological harm.