United States v. Zodhiates

Barrington D. Parker, Circuit Judge:

Defendant-Appellant Philip Zodhiates appeals from a judgment of conviction in the United States District Court for the Western District of New York (Arcara, J .).

*140He was convicted of conspiring with and aiding and abetting parent Lisa Miller to remove her seven-year-old child from the United States to Nicaragua in order to obstruct the lawful exercise of parental rights by Miller's civil union partner, Janet Jenkins, in violation of the International Parental Kidnapping Crime Act ("IPKCA").See 18 U.S.C. §§ 371, 1204, and 2.

Zodhiates contends that the…