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Posts from the ‘Children’ Category

Court Rebukes Father Bent on Cutting Off Daughter’s Support

Close-up of assorted Canadian paper currency

Close-up of assorted Canadian paper currency

Court Rebukes Father Bent on Cutting Off Daughter’s Support

By definition, the role of family law judges is to be fair, impartial and unbiased. But it’s safe to speculate that they routinely see a good deal of needless legal wrangling from litigants. Faced with the fruitless and unnecessary protraction of proceedings – often spurred by one party’s intractable desire to “make a point” or “get even” – sometimes judges will express their exasperation.

This judicial frustration was evident throughout the decision in VanSickle (Elms) v. VanSickle, where the judge set the stage with the following opening words:

This is a family tragedy. The [father’s] relationship with his two children, … is now irreparably shattered. The parties have spent money they could ill afford on four days of trial wherein the [husband] has done his utmost to convince the court that his daughter, a university student, is no longer a dependent and not entitled to any support from him. ….

The parents had divorced in 1996 after 10 years of marriage. By court order in 2000, to which both father and mother agreed, the father’s access to the two children was terminated and he was ordered to pay support of about $585 per month, which the father dutifully paid.

The court order terminated the father’s access to the children, but he was claiming that they had severed ties with him, and that as a result he should no longer be obligated to pay child support for them. Since that order, he had made no effort to contact them, either in person, by telephone, e-mail, letters or cards. One of the children, a son aged 23, was financially independent and no longer needed support.

However, the other child, a daughter also in her 20s, had tried to get in touch with the father in 2007, in the hope that he would help with her university costs. He did provide $600 for the first semester but declined to help beyond that, expressing his disappointment that she had not maintained more contact with him. The daughter then dropped out of university and moved back with her mother, who had also been diagnosed with breast cancer around that time.

The father remarried in 2003 and his business – of which he was the sole officer, director, and shareholder — continued to do well (for example, in 2011 he took $70,000 in salary, paid his new wife $45,000, but then kept almost $240,000 in the business by way of retained earnings for that same year). Yet in 2007 – prompted by the daughter’s email request for help with university costs – he instructed his lawyer to contact the mother to ask her consent to have his child support obligations for both children terminated. With respect to the daughter in particular, he claimed that she was at school for most of the year but lived with her boyfriend for the rest of the time, and therefore was no longer in her mother’s charge. Also, he later asked for a repayment of half the child support he had already paid for a certain period up to and beyond 2007. The mother responded by asking for a retroactive adjustment for s. 7 expenses and for his contribution to the children’s post-secondary expenses.

The question for the judge was whether the adult daughter was still a “child of the marriage” in these circumstances, to the point that the father should still support her despite his unwillingness to do so and despite the cessation of a father-daughter relationship between them. (The Divorce Act defines a “child of the marriage” as an offspring who has “not withdrawn from [the] charge” of the parents; moreover the jurisprudence suggests that an adult child regularly attending post-secondary education is not legally considered to have “withdrawn” from the parents’ charge).

The judge found that the daughter was indeed still a “child of the marriage”, and ordered the father to pay retroactive support for 2007 onward. Despite her having to take educational breaks for various valid reasons, once the daughter returned to university in September of 2009, she resumed that status for the purposes of child support entitlement. Applying the established factors in situations involving an adult child in post-secondary education, her education plan was reasonable; moreover she had shown financial self-sufficiency and a determination to finish her program.

In ordering the father to pay, the judge rebuked him for failing to co-operate and for dragging out the proceedings:

With respect to Mr. VanSickle’s conduct, I have no difficulty in finding that he has engaged in blameworthy conduct. He had a positive obligation by court order to disclose not only his income, but the income of his corporation and he did absolutely nothing. Even in the face of demands, he did not properly comply with the disclosure requirements. He knew that his income was higher and yet did nothing to ensure that his children shared in that increase in income.

With respect to the children’s past and present circumstances, this is a situation where an increased amount of support would have had a positive impact on the lives of the children. I accept the evidence of the applicant and the children regarding their lifestyle, the difficulties they had with housing and the financial struggles of the family. If Mr. VanSickle had assisted Jillian with her university expenses in January 2008, she may very well have completed her degree at McMaster. One will never know.

With respect to the non-existence relationship between her and the father, the judge added:

By the time of trial, it was clear that neither [the son or the daughter] is interested in a relationship with their father. At the same time, Mr. VanSickle’s conduct is such that it is not surprising to the court that this is the case. This is not a situation where [the daughter] has unilaterally and without justification terminated her relationship with her father.

First, Mr. VanSickle chose not to see his children. He could have had supervised access to them when he and [the mother] first separated and he chose not to do so. He consented to an order in 2000 which terminated all access to his children. He did nothing to reach out to these children after the date of that order. It was Jillian who made the first overtures towards her father in 2007 when she was seeking financial assistance from him. While it is true that Mr. VanSickle responded to that request and attempted to reinstate his relationship with the children, his efforts, in my view, were minimal at best. …

In the end, and concluding that the husband’s true income would have to be scrutinized and determined (after taking into account retained earnings, income splitting with his new wife, and the validity of certain expenses that were actually deducted for his personal use), the judge held that the daughter was to bear one-third of her own university costs, and that the remainder was to be shared by the parents in proportion to their respective incomes.

For the full text of the decision, see:

VanSickle (Elms) v. VanSickle, 2012 ONSC 7340

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at www.RussellAlexander.com

When Can A Parent Apply For Child Support‬ – video

Wednesday’s Video Clip: When Can A Parent Apply For Child Support‬

In this video we examine how parents who have their children living with them after separation can apply for child support at any time. Usually they apply right after they separate or as part of their divorce application. They often apply for custody and child support at the same time. It is usually best to deal with these matters as early as possible.

Sometimes parents with custody do not want or need child support at first, but later their situation changes. They can apply for child support when the need occurs, even after a divorce and all other matters arising from the separation have been settled.

But if a step-parent is asked to pay support, the more time that has passed since the step-parent had an ongoing relationship with the child, the less likely it is that the court will order support payments. This is especially true if the step-parent’s social and emotional relationship with the child has ended.

A parent can apply for custody and support even while living separately under the same roof after their relationship with the other parent is over. But usually the court will not make any order for custody and support until one parent has actually moved out.

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at www.RussellAlexander.com.

U.S. Judge Sends Kids to Jail for Snubbing Dad

bad boys

U.S. Judge Sends Kids to Jail for Snubbing Dad

We all know that the break-up of a family can be hard on children, partly because they may feel they are being unwillingly wrenched away from one of their parents, or because they may feel they have to “choose” between them. The situation gets even more fraught when the acrimony between parents gets transferred to the children, by way of one parent trying to “poison” the children against the other one.

In a Michigan case heard in late June of this year, the judge concluded that three children had been subject to this sort of “brainwashing” – better known in legal circles as “parental alienation” – by their mother against their father. Against the background of five full years of legal wrangling by the parents, the children (aged 9, 10, and 15, and living full-time with the mother) refused to have anything to do with the father, and would not even talk to him.

Despite placing the blame squarely on the mother for the children’s uncooperative conduct, the judge declared the kids in contempt, primarily for being completely unwilling to establish a healthy relationship with their father. She initially ordered all three to spend the rest of the summer in a juvenile detention facility, and added that they would not be permitted to visit with their mother (who was herself in breach of several court orders). The detention order would be reviewed, the judge said, when the children indicated willingness to at least dine with their father and be “normal human beings”.

The judge made this contentious order over the objections of both parents, but noted that the children were each represented by lawyers who had no concerns about this admittedly unusual ruling.

Needless to say, the judge’s order garnered significant controversy and backlash in the media and among the legal community. The judge subsequently defended her decision to the press, pointing out that this was an unusual scenario and that all other avenues had been exhausted. She also noted that the children were housed in a short-term facility within the juvenile detention center, and not amongst the young criminal offenders.

(In a later development in early July, after the children had already spent a few weeks in juvenile detention, the judge reversed her initial order and had the children transferred to a summer camp instead).

Do you think that the judge went too far in this case? Should kids be strong-armed into maintaining a relationship with one or both of their parents?

For a sampling of some of the media coverage of this story, see these links:

media coverage 1

media coverage 2

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at www.RussellAlexander.com

 

What Are The Child Support Guidelines? – video

Wednesday’s Video Clip: What Are The Child Support Guidelines?

In this law video we review the child support guidelines.

In 1997, the federal government brought in a set of new rules and tables for calculating the amount of support a parent who does not have custody of his or her child must pay to the parent who has custody.

These rules and tables were later adopted by the Ontario government and are set out in the Child Support Guidelines.

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at www.RussellAlexander.com.

Can a Parent Replace Child Support … with Gifts?

child gift

Can a Parent Replace Child Support … with Gifts?

Even for the best-intentioned of parents, the mechanics around fulfilling the obligation to pay child support can be a challenging part of any separation or divorce. If for nothing else, there is the fact that once you blindly hand the money over, you have little control over how (or even whether) it is actually spent to benefit your child. The lack of input and control – and the need to put faith in the integrity and follow-through of the other parent – can be frustrating.

As a support-paying parent it might be tempting for you to take matters into your own hands, perhaps through what I’ll call a self-help “direct delivery” method. For example, you might be tempted to pay (older) children their child support entitlement directly, or buy them needed items yourself, rather than relying on the other parent to use the support money to do so.

Unfortunately – and unless this has been expressly allowed in a court order – this isn’t an option.
In fact, this approach was expressly rejected in an Alberta case called Haisman v. Haisman. The father, who had been in arrears on child support for his daughter to the tune of $14,000, had over the course of a few years spent about $6,000 on clothes and other items for her nonetheless. A lower court judge, in calculating his overall support obligations, had apparently taken into account the $6,000 and reduced the arrears by that amount. The Alberta Court of Appeal found this was an error, stating:

When a mother has custody of a child and a court orders the father to make payments to the mother for the maintenance of that child, it is not open to him to make payments to the child instead. Nor is it open to him to buy things for the child and to claim that the amounts which he spends in this way should be deducted from the maintenance payments which he was ordered to make to the mother. In neither case has he complied with the order of the court. Further, the mother, as the custodial parent, is entitled to decide how maintenance payments for the child will be spent.

As the court in another Alberta decision called Kazeoleas v. Kazeoleas added:

If this were not so, a father could, for example, buy expensive skis for his child and then reduce his maintenance payments by the cost of the skis. The mother would then be left to find the money to house and feed the child without any help from the father. This cannot be right.

This same approach was applied in an Ontario case called Szucs v. Freeman, where the court said:
Gifts to the children do not constitute support to the custodial parent. It is the custodial parent who pays the rent, pays the utilities, purchases the groceries, purchases the children’s clothing, and so on. Gifts to the children do not in any way contribute to the lessening the custodial parent’s obligation in that regard.

These decisions all confirm that a support-paying parent does not have the unilateral right to decide to give gifts or other items in lieu of support, then claim that his or her child support obligations have been satisfied. Nor, for that matter, does that parent get to choose how money that should be earmarked for child support is to be spent by the other parent, which is a topic I will address more fully in an upcoming Blog.
For the full text of the decisions, see:

Haisman v. Haisman, 1994 ABCA 249 (CanLII), reversing 1993 CanLII 6988 (AB QB), leave to appeal to S.C.C. dismissed without reasons, [1995] S.C.C.A. No. 86.

Kazoleas v. Kazoleas, [1997] A.J. No. 820, (July 9, 1997) 9103 00516 and 4803 80820, Edmonton (Alta. Q.B.).

Szucs v. Freeman, 2007 ONCJ 96 (CanLII).

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at www.RussellAlexander.com.

Enforcement of Child Support in Ontario – video

Wednesday’s Video Clip: Enforcement of Child Support in Ontario

In this legal video, we review enforcement in Ontario is done through a provincial government office called the Family Responsibility Office (FRO). The court automatically files all support orders made after July 1, 1987 with the FRO. Separation agreements can also be filed there if they have been filed with the court and then mailed to the FRO.

The parent who is to pay support is told to make all support payments to the FRO. When the FRO receives a payment, it sends a cheque to the parent with custody, or deposits the money directly into that parent’s bank account. It only does this after it has received the money from the paying parent.

If a payment is missed, the FRO takes action to enforce the order or agreement. To do this, the FRO needs as much up-to-date information about the paying parent as possible. This includes his or her full name, address, social insurance number, place of employment or business, income, and any property he or she owns. The information about the paying parent goes on a Support Deduction Information Form which is available at the court. This form is given to the FRO along with the support order or agreement. It is important to update this form whenever the information changes.

 

Once the order or agreement is filed with the FRO, then it is the FRO, not the other parent, that is responsible for any actions taken to enforce it.

Sometimes parents receiving support withdraw from the FRO because it is easier to receive payments directly from the other parent. But if problems arise later, and they want to re-file with the FRO, they might have to pay a fee to do this.

Parents who have an obligation to pay support should also know that the FRO cannot change the amount that the order or agreement says they have to pay. If they think that a change in their financial situation justifies a reduction in the amount of support they should pay, they must get a new agreement or go to court to get the support order changed.

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at www.RussellAlexander.com.

Is Summer Camp or Other Activities a “Necessity” for Kids? (Or Only for Parents’ Sanity?)

summer camp

Is Summer Camp or Other Activities a “Necessity” for Kids? (Or Only for Parents’ Sanity?)

The official start of summer is fast approaching. It’s a time when, as parents, we strive to keep children busy with various sports and activities, particularly through the long hot months of their summer vacation from school.

You might call these activities are “necessities” – at least from the point of view of parents who must juggle work and childcare responsibilities (and otherwise endure the frustration of having bored kids underfoot from June through early September!).

But – in the context of determining how and by whom they are paid for – are they really necessities in the legal sense?

The recent Ontario decision in Sutej v. Sutej tackles a scenario where the divorced parents of a boy disagreed on whether his soccer camp and other activities were something towards which the father should have to contribute financially. From a legal perspective the test was whether these activities fell under “section 7 expenses” under the Child Support Guidelines, which covers the payment of what are known as “extraordinary expenses” for extracurricular activities. Those expenses – which are above-and-beyond basic child support obligations – are to be shared by the parents in proportion to a number of variables, including their respective incomes. The Guidelines also clarify that a court must assess the appropriateness of any such “extraordinary expenses” by considering several factors, including the nature and number of extracurricular activities and their overall cost.

In Sutej, the mother had enrolled their couple’s son in a soccer camp in the summer, as well as in other summertime and year-round activities including both soccer and gymnastics. The father, however, resisted paying for these kinds of expenses for his son; he also objected to the fact that the mother was choosing what extracurricular activities the boy would be enrolled in, without checking with him first and obtaining his advance approval.

In this context, the court’s mandate was to determine whether such camp costs (and similar activities) met the test of being “extraordinary expenses” within the meaning of section 7 of the Guidelines.

Firstly, the court confirmed that the mother lacked the absolute right to enroll the child in a multitude of activities, and then ask the father for a contribution in paying for them. Quoting from another decision called Forrester v. Forrester the court confirmed that “the Guidelines do not grant a license to a custodial parent to inject a child into lavish additional activities and demand automatic payment.” Instead, the court emphasized, the expenses sought by the mother from the father to pay for the extracurricular activity must meet the threshold tests of “necessity” and “reasonableness”. Also, they must represent unusual costs that are not otherwise covered or subsumed in the ordinary payments that are paid by the parents.

Applying these principles to the present case, the court found that the costs to enroll the son in soccer camp and in his current roster of activities were not “extraordinary” in line with the Guidelines threshold. The court wrote:

“… as enjoyable and instructive as they may be, I do not consider them to be “reasonably necessary” to require [the father] to contribute to them. [The father] may wish to do so voluntarily, but that is between [the father and the mother], and ultimately, [the father and the son].”

Practically speaking, however, the court recognized that such extraordinary expenses may crop up from time to time as the child got older. To eliminate any future dispute between the parents, it ordered the father to pay a set amount each month to represent section 7 expenses for extracurricular activities. The court explained that part of its ruling this way:

In today’s changing world, [the mother] may find that [the son] would benefit from new and changing experiences to open the world up to him. Subject to any further order [the father] may seek as to what those experiences should or should not be, rather than give vent to either party and their respective personalities with respect to each activity as it comes up, I order [the father] to pay $50 a month for section 7 expenses to meet his responsibility for making contributions to [the son’s] extracurricular activities.

The court added that if other section 7 expenses arose in the future that required a greater contribution, then the parties could go back to court to increase the father’s share.

For the full text of the decision, see:

Sutej v. Sutej, 2015 ONSC 2064 (CanLII)

Forrester v. Forrester, 1997 CanLII 15466 (ON SC), [1997] O.J. No. 3437

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at www.RussellAlexander.com

Who Pays Child Support in Ontario? – video

 

Wednesday’s Video Clip:Who Pays Child Support in Ontario?

In Ontario, all parents have a legal responsibility to support their dependent children to the extent that they can. In this video, we examine who is responsible to pay child support and why.

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at www.RussellAlexander.com.

How Blameworthy Conduct Can Affect Retroactive Child Support

bad conduct

How Blameworthy Conduct Can Affect Retroactive Child Support

Perhaps it’s trite to say: Divorce does not bring out the best in people. The Ontario family courts are filled with litigation that is often spurred or exacerbated by bad behaviour, lack of cooperation, and unreasonable posturing by one or both parents.

In response, courts are certainly authorized to impose sanctions for various misconduct (for example in the form of granting orders to strike pleadings, impose costs, or declare a party to be in contempt). However, a less-tangible (but still permissible) method for addressing a family litigant’s bad behaviour comes in the form of an “adjusted” child support award – one that takes into account the paying parent’s blameworthy conduct.

This was illustrated in the Supreme Court of Canada called (D.B.) v. G. (S.R.), where the Court considered application by one parent for retroactive child support from the other. The Court turned its focus on precisely how and to what extent a family court should take into account a paying parent’s blameworthy conduct when evaluating the amount retroactive child support he or she should be required to pay.

In this regard, the Court made the following observations:

• “Blameworthy conduct” is anything that privileges a paying parent’s own interests over the right of his or her children to an appropriate amount of child support.

• No level of blameworthy behaviour by parents should be encouraged.

• Even if the paying parent does nothing to actively avoid his or her child support obligations, he or she might be acting in a blameworthy manner by consciously choosing to ignore those obligations.

• In other words, a paying parent who knowingly avoids or diminishes his or her support obligation to the children of the relationship should not be allowed to profit from that conduct.

• When considering the appropriateness of a retroactive award, family courts should not hesitate to take into account a paying spouse’s blameworthy conduct.

• In fact, courts should take “an expansive view” of what constitutes blameworthy conduct for these purposes.
There is no bright-line test as to what amounts to blameworthy behaviour in the family law context. However, the Court gave some examples of the type of conduct to avoid, stating:

• A paying parent cannot hide his or her pay increase from the parent who receives the child support, in the hopes of avoiding larger child support payments.

• Nor can a paying parent cannot intimidate a recipient parent in order to discourage him or her from bringing a child support application.

• A paying parent cannot mislead the other parent into believing that child support obligations are being met, when he or she knows that they are not.

For the full text of the decision, see:

S. (D.B.) v .G. (S.R.), 2006 SCC 37 (S.C.C.)

 

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at www.RussellAlexander.com.

When Does a Seriously-Ill Adult Child Stop Needing Support?

adult child

When Does a Seriously-Ill Adult Child Stop Needing Support?

In a brief decision from a few weeks ago, the court considered a narrow but interesting point: For an adult chid with a serious disease, when does he or she stop being a “child of the marriage” for child support purposes?

In Furlani v. Furlani, the father brought a motion to terminate the child support he had been paying as part of his divorce from the mother. The mother opposed the request as premature: she was concerned that the health of their adult daughter, who had Cystic Fibrosis, might not remain be stable enough in the future to warrant terminating support now.

The court reviewed the evidence jointly tendered by the former couple. In the course of finding that the daughter no longer fit within the definition of “child of the marriage” under the Divorce Act, and that the father’s support obligations should therefore be terminated, the court summarized the evidence and its conclusions this way:

[The daughter] was diagnosed at age three with cystic fibrosis. Her mother testified about the difficulties [the daughter] experienced as a child and the efforts that [the mother] had to make to get the doctors to finally arrive at the correct diagnosis. I understand very well the effect that diagnostic testing and treatment of young children can have on the child and the parents, alike.

I also understand how difficult it can be for the parents of a child who has gone through such testing and treatment to let go, once the child has reached adulthood. There is always a fear that the past will return with a vengeance. In [the daughter’s] case, it is a certainty that her illness will one day pose great challenges. In fact, she faces many challenges today, including requiring treatment for lung and sinus infections.

However, at present, [the daughter] is overcoming these challenges. She is now 21 years old. She lives in southern Ontario with a partner, with whom she is romantically involved. Although both her parents share concerns about it, [the daughter] has entered into a formal contractual relationship as an apprentice to learn the tattoo trade. While she is not yet earning income from that trade, [the daughter] does have income in the form of Ontario Disability Support Program (ODSP) payments that she has been receiving since she turned 18.

The court added that while the Divorce Act’s “child of marriage” definition excludes a child over 18 who is “unable, by reason of illness, disability or other cause” to withdraw from her parents charge or to obtain the necessities of life, the daughter in this case did not fit that category; indeed the court noted that “[s]he appears to be a determined young lady.” It also pointed out that the parents’ provision of financial assistance from time-to-time did not change that assessment; the court observed “this is something that parents of young adults are often called upon to do.”

Finally, while acknowledging that the parents were concerned about their daughter’s future, the court pointed out that it was charged with making a determination based on her present situation. In this particular case, the daughter was able to remove herself from her parents’ charge and would continue to be able to do that for the foreseeable future; the father should no longer be obliged to pay support for her. Another motion could be brought in the future, if her health and abilities were to change.

For the full text of the decision, see:

Furlani v. Furlani, 2015 ONSC 1582

 

At Russell Alexander, Family Lawyers our focus is exclusively family law, offering pre-separation legal advice and assisting clients with family related issues including: custody and access, separation agreements, child and spousal support, division of family property, paternity disputes, and enforcement of court orders. For more information, visit us at www.RussellAlexander.com.