R.V.W. v C.L.W., 2019

The parties commenced cohabitating in Calgary in about 2015. The father, an American citizen, had overstayed his visitor’s visa. The parties married in January 2017 and took other unsuccessful steps to allow him to remain in Canada. The father was denied permission to stay, and he returned to the United States in February 2017. The mother, a Canadian citizen, followed him to Texas, where their child was born in September, 2017.