Sterzinger v. Efron

Richard Sterzinger, a German national, met Madeleine Candelario, a Puerto Rican citizen, while both were graduate students at the University of Miami School of Law. They married in Puerto Rico in 1978 and moved to West Germany where their only child, Sibyl, was born. The couple separated in 1982. Madeleine returned to Puerto Rico with the child. She was awarded child custody pursuant to a 1983 German divorce which incorporated a property settlement and child custody agreement.

After a dispute arose over visitation arrangements, Richard filed a petition in the Superior Court of Puerto Rico,…