In Croll v. Croll (2d Cir. 2000) 229 F.3d 133, the court rejected the notion that a child's removal in violation of a ne exeat clause constituted a violation of the non-custodial parent's custody rights. Croll held that a ne exeat clause does not confer custodial rights upon a non-custodial parent. Croll held "that rights of access do not constitute rights of custody within the meaning of the Hague Convention, even when coupled with a ne exeat clause." (Id. at p. 135.)