american jailed in japan for kidnapping his kids, w/ a twist

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Originally Posted by CNN
TOKYO, Japan (CNN) -- Had this parental abduction drama played out in the United States, Christopher Savoie might be considered a hero -- snatching his two little children back from an ex-wife who defied the law and ran off with them.
A Tennessee court awarded Christopher Savoie custody of his son, Isaac, and daughter, Rebecca.

A Tennessee court awarded Christopher Savoie custody of his son, Isaac, and daughter, Rebecca.

But this story unfolds 7,000 miles away in the Japanese city of Fukuoka, where the U.S. legal system holds no sway.

And here, Savoie sits in jail, charged with the abduction of minors. And his Japanese ex-wife -- a fugitive in the United States for taking his children from Tennessee -- is considered the victim.

"Japan is an important partner and friend of the U.S., but on this issue, our points of view differ," the U.S. Embassy in Tokyo said Tuesday. "Our two nations approach divorce and child-rearing differently. Parental child abduction is not considered a crime in Japan."

The story begins in Franklin, Tennessee, with the divorce of Savoie from his first wife, Noriko, a Japanese native.

The ex-wife had agreed to live in Franklin to be close to the children, taking them to Japan for summer vacations.

But in August -- on the first day of classes for 8-year-old Isaac and 6-year-old Rebecca -- the school called to say they hadn't arrived.

Worried, Savoie called his ex-wife's father in Japan, who told him not to worry.

"I said, 'What do you mean -- don't worry? They weren't at school.' 'Oh, don't worry, they are here,' " Savoie recounted the conversation to CNN affiliate WTVF earlier this month. "I said, 'They are what, they are what, they are in Japan?' " Video Watch Savoie talk about how much he misses his kids »

After the abduction, a court in Williamson County, Tennessee, granted Savoie full custody of the children. And Franklin police issued an arrest warrant for his ex-wife, the television station reported.

But there was a major hitch: Japan is not a party to the 1980 Hague Convention on international child abduction.

The international agreement standardizes laws, but only among participating countries.

So while Japanese civil law stresses that courts resolve custody issues based on the best interest of the children without regard to the parent's nationality, foreign parents have had little success in regaining custody.

Japanese family law follows a tradition of sole custody divorces. When a couple splits, one parent typically makes a complete and lifelong break from the children.

The International Association for Parent-Child Reunion, formed in Japan this year, claims to know of more than 100 cases of children abducted by noncustodial Japanese parents.

And the U.S. State Department says it is not aware of a single case in which a child taken from the United States to Japan has been ordered returned by Japanese courts -- even when the left-behind parent has a U.S. custody decree.

Saddled with such statistics and the possibility of never seeing his kids again, Savoie took matters into his own hands.

He flew to Fukuoka. And as his ex-wife walked the two children to school Monday morning, Savoie drove alongside them.

He grabbed them, forced them into his car, and drove off, said police in Fukuoka.

He headed for the U.S. consulate in Fukuoka to try to obtain passports for Isaac and Rebecca.

But Japanese police, alerted by Savoie's ex-wife, were waiting.

Consulate spokeswoman Tracy Taylor said she heard a scuffle outside the doors of the consulate. She ran up and saw a little girl and a man, whom police were trying to talk to.

Eventually, police took Savoie away, charging him with the abduction of minors -- a crime that upon conviction carries a prison sentence of up to five years.

The consulate met with Savoie on Monday and Tuesday, Taylor said. It has provided him with a list of local lawyers and said it will continue to assist.
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Meanwhile, the international diplomacy continues. During the first official talks between the United States and Japan's new government, the issue of parental abductions was raised.

But it is anybody's guess what happens next to Savoie, who sits in a jail cell