Read the passage below and answer the question.
Zulima, age 13, lives with her father Joseph in Corto Maltese, a country in Africa where young women are kidnapped, forced to marry men and forced to bear them children. Joseph does not want his daughter to live this kind of life. He manages to scrape together $420 U.S. dollars to send Zulima to America. He pays Salim, who promises to take Zulima to her relatives in the US. Although Salim does bring Zulima to America, he decides to keep her for himself. Zulima writes her father and tells him of her fate.
Shortly thereafter, Joseph arrives in America and successfully recuses his daughter. Zulima and her father then sue Salim in an American court for the return of the $420.
What issues are Zulima and Joseph likely to face in an American court?