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The Court then issued a verbal order from the bench that the boy was not to be circumcised. The court then followed that with a written order on 2 June 2009, in which the court found that a substantial change of circumstances had occurred and ordered an investigation by an independent child custody evaluator for a future evidentiary hearing.<ref name="geisheker2009" />
The father, facing an evidentiary hearing that he was likely to lose, voluntarily surrendered custody of Misha/Jimmy on .
A long-running legal case in the United States, finally resolved in 2009, when courts in the state of Oregon ruled that a parent could not compel a child over which he had custody to get circumcised against the boy's will. The case is of interest in its potential to limit the power of parents to impose circumcision and similar physical alterations on children and in its implicit recognition that children have their own rights – to physical integrity and freedom of conscience and religion – independently of their parents' belief.