The U.S. Court of Appeals for the Tenth Circuit has affirmed the dismissal of a federal habeas corpus petition in *Amboh v. Haney*, a complex child custody dispute that highlights the jurisdictional limitations of federal courts in family law matters.
Kandra Amboh filed the appeal after losing custody of her minor children in Utah state court proceedings. The case began when Nicholas Haney petitioned the Utah state court for sole custody of his minor children and obtained a protective order for the children against Amboh. The state court granted both requests, awarding Haney custody and issuing the protective order.
Following the adverse state court ruling, Amboh attempted to challenge the custody determination through federal court by filing a habeas corpus petition seeking the return of her children. She named Nicholas Haney, Jeffry Ross, and Erin Rawlings as defendants in the federal action filed in the U.S. District Court for the District of Utah.
The federal district court proceedings moved swiftly toward dismissal. A magistrate judge issued a recommendation that the habeas petition be dismissed for lack of jurisdiction, finding that federal courts generally do not have authority to review state family court custody determinations through habeas corpus proceedings. Significantly, Amboh did not file any objections to the magistrate judge's recommendation, effectively waiving her right to challenge the recommended dismissal.
The district judge adopted the magistrate's recommendation and dismissed the habeas petition. This dismissal prompted Amboh to file an appeal with the Tenth Circuit Court of Appeals, seeking to overturn the lower court's decision and pursue her federal challenge to the state custody ruling.
The Tenth Circuit panel, consisting of Circuit Judges Bacharach, Moritz, and Rossman, reviewed the case without oral argument. The court noted that neither party requested oral argument and determined that oral argument would not assist in deciding the appeal. Instead, the panel decided the matter based on the written record and the parties' briefs, following established appellate procedures.
In their order and judgment filed Jan. 8, 2026, the Tenth Circuit affirmed the district court's dismissal of the habeas petition. The appellate court's decision effectively ended Amboh's attempt to use federal court jurisdiction to challenge the Utah state court's custody and protection order determinations.
The case illustrates the strict jurisdictional boundaries that separate state family courts from federal court authority. Federal habeas corpus relief is typically reserved for cases involving constitutional violations in criminal proceedings or extraordinary circumstances where state remedies are inadequate. Child custody disputes, even those involving allegations of improper proceedings, generally remain within state court jurisdiction under principles of federalism and comity.
The Tenth Circuit's ruling reinforces the principle that federal courts should not interfere with state family court proceedings absent exceptional circumstances. State courts maintain primary jurisdiction over family law matters, including child custody determinations, protective orders, and related domestic relations issues.
For parents involved in custody disputes, the decision emphasizes the importance of pursuing remedies within the state court system rather than attempting to relitigate custody matters in federal court. State courts typically provide adequate appellate procedures for challenging custody determinations, and federal intervention is rarely appropriate or available.
The court's order specifically noted that the decision is not binding precedent except under the doctrines of law of the case, res judicata, and collateral estoppel. However, the ruling may be cited for its persuasive value in similar cases involving federal court jurisdiction over state family law matters.
The case also demonstrates procedural consequences when parties fail to object to magistrate judge recommendations. Amboh's failure to file objections to the magistrate's dismissal recommendation likely weakened her position on appeal, as courts generally require parties to preserve issues for appellate review through proper objections at the district court level.
While the specific details of the underlying Utah state court proceedings and the protective order are not fully detailed in the appellate record, the federal court's decision focuses strictly on jurisdictional questions rather than the merits of the custody dispute itself.
The Tenth Circuit's affirmance closes this chapter of federal litigation, leaving the state court custody and protection orders in place. The decision serves as a reminder that federal courts maintain limited authority over family law matters, with state courts retaining primary responsibility for resolving custody disputes and protecting children's welfare through appropriate legal mechanisms.