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If the Parties Settle, Who’s Entitled to Legal Costs?

If the Parties Settle, Who’s Entitled to Legal Costs? 

The father had applied to the court for an order setting up an equal time-sharing parenting plan for his 5-year old son, and to have his child support obligations adjusted accordingly.  He felt this would allow the child to spend the maximum amount of time with both him and the child’s mother.

However, he waited until the final settlement conference to consider withdrawing his application – then decided against.  Instead he fired his lawyer.  He then abandoned the claim entirely, himself.

He and the mother ended up reaching an agreement on consent, which the court said “closely resembled” the parenting plan that they had in the first place, as part of their separation agreement from three years earlier.

In light of the father’s fruitless and excessive application, and the unneeded legal fees and court time it required, the mother asked for her full costs of over $12,200.

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In response, the father asked for his costs of over $7,100, on the basis that he was forced to bring the application because the mother backed out of earlier negotiations after he accepted her settlement proposal.   He felt her position was unreasonable, and that he ended the court proceedings because he “did not have the energy to continue the fight.”

The court was asked to decide which of them was entitled to legal costs from the other.  It started by confirming the basic principles on how legal costs are to be awarded in Family Law proceedings, including the presumption that the successful party is entitled the costs of a motion, enforcement, case or appeal.  Plus, a party who has behaved unreasonably may be deprived of all or part of the costs to which they would otherwise be entitled.

However, there are dedicated costs rules covering situations where the parties end up settling their issues with each other.  As the court wrote:

Awarding Costs in a Case that has Settled:

Courts have often held that where parties reach a settlement, the court should be slow to award costs in favour of one of the parties unless there are compelling reasons to do so. Courts want to encourage parties to settle their cases in order to avoid costs. It is also sometimes very difficult to determine who is the “winner” and the “loser” in a negotiated settlement. …

However, there are cases when costs may be awarded when parties reach a signed agreement. There may be instances where a settlement is a “clear capitulation” by one party in favour of another, and it is obvious who the successful party is in the litigation. …

Simply because the parties have settled, this does not mean that a court cannot still undergo a full costs analysis, taking into account the usual factors.  A court may even consider a party’s behaviour in actually settling the case, adding:

But if a party eventually makes a good litigation choice by signing Minutes, that epiphany doesn’t automatically wipe out any history of bad litigation choices which would otherwise justify costs. Settling in the face of the inevitable may be little more than damage control.

If a party brings a motion asking to change almost everything, and at the last minute signs a Consent which changes almost nothing, how can they possibly argue that a judge will have a hard time figuring out who was successful?”

In this case, the settlement agreement was a “clear capitulation” by the father; he had completely abandoned his claim for equal shared parenting and a reduction of child support on the last hearing day, after firing his lawyer.  He had also refused to exercise additional access to the child gradually, unless there was a full and equal parenting plan in place by court order or agreement.  In fact, there were days leading up to the settlement where he could have spent more time with the child, but refused to do so.

As the court put it:

The father’s position was “all or nothing”. There was no middle ground for him. When he did not achieve “all” immediately, he withdrew his claim and blamed the mother.

The father’s position was not child-focused. It was about his rights as a father and not about what was in his child’s best interests. …

On the other hand, the court decided the mother had behaved reasonably throughout, and had been “put to great expense” in responding to the father’s unreasonable application, which was “an entirely wasted application and court process.”

As the successful party, the mother should be entitled to some costs, but not the full $12,200 claimed because she had never served a formal offer to settle.  Instead, the court order the father to pay her $6,000.

For the full text of the decision, see:

Mitchell v. Longley, 2019 ONCJ 161 (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 RussellAlexander.com

 

 

What’s the Legal Effect of Setting a Domestic Agreement Aside Pending Trial?

In a recent case called MacLeod v. MacLeod, the court focused on a provision in the Ontario Family Law Act (namely, section 33(4)) that gives a court the clear power to overrule what spouses may have intended in their signed, written domestic agreements.

But what became less clear, is what the court’s proper legal approach should be when faced with a spouse who asks to have a domestic agreement set aside on an interim basis, (i.e. temporarily) until a full hearing into the issue can be held.  For example, if a court agrees to temporarily set aside a separation agreement until trial, and that agreement covers spousal support amounts, then how are support levels to be calculated in the meantime?

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In MacLeod, a couple had signed a marriage contract addressing the issue of spousal support in the event they separated.  The contract called for the husband to top-up the wife’s monthly income to a certain level, and to pay her a $150,000 lump-sum, among other things.

A few years later they did separate, but the wife asked the court to set that marriage contract aside, on the basis that she did not understand it at the time she signed it, and did not obtain legal advice prior to doing so.   She made this request, together with a bid for short-term spousal support, on an interim hearing, meaning one that was well in advance of a full trial of all of their issues (which would take place later).   In other words, she was asking the court for a temporary order at this stage.

The husband objected.  He argued that – depending on whether the wife was successful in having all or part of the contract set aside – such an order could throw his obligations into some uncertainty, and compromise him financially.  The court explained the conundrum:

… [U]ntil it is set aside, there is a presumption that the parties’ executed marriage contract is valid. Where one party seeks to set aside a domestic contract and seeks interim support, support should be ordered in accordance with the marriage contract. Courts should exercise great caution in granting interim relief that contradicts the terms of a contract signed by the parties.

If I were to presume, on a temporary basis, that the marriage contract is valid, and limit the mother’s spousal support entitlement to what the contract provides (an amount sufficient to top up the mother’s income to $36,000 per year), then it seems to me that I should also order the father to immediately pay the $150,000 lump sum as well.  The father objects to paying this lump sum on a temporary basis for two main reasons. First, he takes the position that the mother is a significant flight risk, and receiving this important payment will only increase her ability to remove the child from Canada.  In addition, he states that if the marriage contract is ultimately declared invalid, he will have paid to the mother a significant advance towards future spousal support which he may never be able to recover down the road.

This raised the legal question of how, pending that full hearing, the court should treat the agreement the couple had reached, and whether all or parts of it should be enforced for the time being.

Essentially, the court took the middle-road:  It concluded that husband’s concerns over the $150,000 lump-sum payment were “compelling”, and temporarily relieved him of the obligation to make that payment until the later hearing.  However, he was still ordered to pay spousal support in a set amount, as the marriage contract called for.  This would allow the wife to maintain her existing lifestyle until the trial, which was the primary goal of interim spousal support at this stage.

From a practical standpoint, this also made sense:  If the couple’s marriage contract was set aside at trial, then the husband’s spousal support obligations could be adjusted retroactively by the trial judge.  Conversely, if the contract was upheld at trial, then any overpayment the husband made in the interim could be offset against the $150,000 he still owed under it.

For the full text of the decisions, see:

MacLeod v. MacLeod, 2019 ONSC 2136 (CanLII)

Balsmeier v. Balsmeier, 2014 ONSC 5305 (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 RussellAlexander.com

The Laws Around the Non-Consummation of a Marriage: Which Jurisdiction’s Laws Govern

The Laws Around the Non-Consummation of a Marriage: Which Jurisdiction’s Laws Govern

In a case called Sahibalzubaidi v. Bahjat, the wife asked the Ontario court to annul her marriage to the husband on the basis that they had never consummated it.   The civil wedding ceremony took place in Malaysia and was duly registered there, but immediately afterwards she returned to her home in Canada to await her new husband’s arrival, under the immigration sponsorship process.

The non-consummation was on account of the wife’s strongly-held religious belief that the Malaysian ceremony represented only the civil portion of an Islamic marriage ceremony.  As a devout Muslim, she believed that she was prohibited from consummating the marriage until the couple had taken two further steps, namely: 1) receiving a religious blessing, and 2) participating in a public marriage feast.

Those two added steps never took place, because soon after the husband arrived in Canada the wife and her family concluded he was abusive. The wife stated she would never have married him if she had known of his true character beforehand. (Which was a factor that the court considered in another part of this judgement on the annulment issue, which we discussed in an earlier blog here).

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The question for the court was whether the wife’s annulment application to the Ontario court should be granted.  The court held that it should.

The ceremony took place in Malaysia, but the wife’s pre-marital domicile was Ontario. The laws of Ontario therefore governed the issue of how the non-consummation of the marriage affected the wife’s ability to get an annulment.  Those laws recognized that an annulment could be granted on the basis that the marriage was never consummated due to the wife’s strongly-held religious beliefs as to the need for a religious blessing and the public marriage feast to make the marriage valid.

(This was distinct from annulling the marriage because those added steps had not taken place;  the court found there was insufficient evidence on how or whether the legal validity of the marriage was impaired by the failure to perform all three components of the Islamic ceremony).

For the full text of the decision, see:

Sahibalzubaidi v. Bahjat, 2011 ONSC 4075 (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 RussellAlexander.com

Did Husband’s Poor Character Justify Marriage Annulment Based on Fraud?

Did Husband’s Poor Character Justify Marriage Annulment Based on Fraud? 

In a case called Sahibalzubaidi v. Bahjat, the court grappled with whether to annul the marriage between a woman and a man based on an unusual ground, namely “fraud”.   The woman claimed that in order to induce her to marry him, the man and committed fraud against her and her father, by misrepresenting that he had good character when he did not.

The man and woman were merely passing acquaintances while attending the University of Malaysia at the same time.  As a devout Muslim, she could not date or have an in-depth conversation with him in that environment.   However, when she returned to Canada to join her family, they continued to exchange emails and over time this led a discussion of marriage.  To her, “the most important thing in a potential husband was and is that he be honest, kind, moral and upright character and share my religious values which involve respecting me as his wife”, as she later told the court.

The man proposed to the woman by e-mail.  She accepted – subject to her father giving his consent, especially since she was his only daughter.  The father interviewed the man and his parents, and they gave him their assurances that the man possessed the character and qualities of a suitable husband for the woman.

The father approved the marriage, which took place in the customary manner involving both a civil ritual and a religious one. During that ceremony, the man promised to keep the woman safe, respect her, and take care of all aspects of her life.   He also directly promised the woman’s father that he would keep her safe and respect her.   The imam, who performed the marriage ceremony, told the man that if he tried to hurt the woman, she would have the right to make the marriage fasid, which means to have it annulled.

The court described the woman’s evidence as to what happened soon after:

[The woman] deposes that upon his arrival in Canada, [the man’s] true character emerged and had she known this she would have never agreed to marry him. [The man] breached his promise to keep her safe and respect her. … [T]he woman states:

He began to assault her, once even dragging her onto the front lawn of her parents’ house where everyone could see, which was a particularly debasing and humiliating act against someone of the [woman’s] cultural and religious background. The [man] threatened her and had her call his parents in Iraq to ascertain that, indeed, he had shot his father and broken his mother’s arm. The [woman] confirmed these facts with members of the [man’s] family, other than his mother and his father. He also implied that should she ever disobey him, a similar fate would await the [woman]. He would repeat the same complaint or instruction to her, not simply ad nauseum, but literally a hundred times a day in a succession. He refuses to recognize that he has any kind of personality disorder and will not under any circumstances obtain professional help in order to deal with it.

In light of these developments, the woman asserted that both the man and his parents deceived her and her father.  She asked the court to concluded that these facts were tantamount to fraud, which could form the basis  for annulling the marriage entirely.

The court noted that fraud does not usually vitiate a marriage, unless it induces an “operative” mistake,  for example one relating to a party’s identity, or a mistake in understanding that the ceremony that is taking place is a legal marriage.

The mistaken identity factor that could justify an annulment might arise if, for example, party A is induced to marry B, believing that she is marrying C.  Here, there was no such deception as to the man’s identity per se; the misrepresentations as to his character or personality traits did not fall within the traditional category of fraud.

The court accordingly rejected the woman’s annulment argument on this ground (although it did agree annul the marriage on one of the other grounds she raised, namely non-consummation, and failure to comply with certain religious requirements).

For the full text of the decision, see:

Sahibalzubaidi v. Bahjat, 2011 ONSC 4075 (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 Russellalexander.com

Challenging a Domestic Contract – Are its Terms Still Valid Pending Trial?

Challenging a Domestic Contract – Are its Terms Still Valid Pending Trial?

As readers of my Blog will know, “domestic contracts” (which include separation agreements and marriage contracts) are essentially signed, written legal contracts that embody the negotiated agreement between spouses in the event of their separation or divorce.  Among other things, they typically include provisions relating to how much post-split spousal support is to be paid, and by whom.

A well-drafted domestic contract will withstand a court’s scrutiny, and its terms may even be incorporated into an eventual divorce order made by the court.  But not all domestic contracts pass this test – one or both spouses may decide to challenge the validity of the agreement they negotiated, and may go to court for a temporary ruling on whether its provisions should be enforced pending a fuller trial, when all their issues relating to the separation or divorce can be finally addressed.

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These kinds of contract-challenge scenarios give rise to two interesting legal questions:

Question 1:  Do the support-related provisions of a domestic contract remain effective pending a court’s later determination of whether they are legally valid?

Yes.  In a case called Balsmeier v. Balsmeier, the court stated that there is a legal presumption that the marriage contract executed between a couple is valid.  So if one of them asks the court to set it aside, and requests interim support until the rest of their issues can be determined later at trial, then the court should normally order that support in keeping with what the parties agreed to in the contract.  In other words, the court should be reluctant to order interim relief that contradicts what the parties themselves agreed to in the signed contract.

Question 2:  Can a couple add a provision to domestic contract that effectively ousts a court’s authority to change or set aside other provisions that relate to support?

No. If a domestic contract includes a provision for support, or a waiver of a right to support, then the court can freely set it aside and make its own support determination – even though the contract itself contains an express provision trying to preclude the court’s power to do so under the Family Law Act (FLA). There are three situations in which a court can do this:

  • Where the provision for support, or the waiver of the support right, results in unconscionable circumstances,
  • The support provision is in favour of a dependent who qualifies for an allowance for support out of public money, or the waiver is by or on behalf of this kind of dependant, or
  • There is default in the payment of support under the contract at the time the application is made.

In an upcoming Blog, we will take a look at how this power can be wielded by a court, and applied practically in the face of rather onerous domestic provisions that are being challenged at an interim stage pending trial.

For the full text of the decision, see:

Balsmeier v. Balsmeier, 2014 ONSC 5305(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 RussellAlexander.com

 

Gambling, Drinking and Affairs – How do Ontario Divorce Courts Treat Spouses for their Misdeeds?

Gambling, Drinking and Affairs – How do Ontario Divorce Courts Treat Spouses for their Misdeeds?

A case called Malandra v. Malandra, where the court found that – for the purposes of deciding whether their Net Family Property (NFP) should be unequally divided – the husband should not be held solely accountable for certain bad business investments.

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This question of whether the NFP should be divided unequally comes up often: among other things courts must consider whether one of the spouses behaved in a manner that makes an even split unfair. Here are some of the categories of spousal misdeed that can come under the court’s scrutiny:

Learn more:

Property Division 101: Introduction to Sharing Family Property in Ontario Divorce

“Property” or “Income”? Appeal Court Rules on Structured Settlement Annuities

Is Husband’s Payment of 230 Gold Coins Under Islamic Marriage Contract Excluded from Wife’s Property?

  1. Reckless Investing

In a case called Lamantia v. Solarino, 2010 ONSC 2927, the question was whether the husband should be held accountable for deceit and various financial misconduct designed to hide his reckless investments in the stock market. He had forged the wife’s signature, and had borrowed from credit cards for which she became liable without her knowledge. He also took active steps to keep the wife from learning the true state of their financial affairs; for example, he made sure their bank statements were sent to another address. Furthermore, he continued to play the stock market even though the wife had asked him to stop. Those bad investments led to significant capital losses for the couple.

In finding that the NPF should not be equally divided, the court found that the husband had engaged in a pattern of deceit and engaged in conduct that made it unconscionable for the NFP to be divided equally.

Learn more:

Should Support-Paying Ex-Husband Be Saddled with Ex-Wife’s Financial Irresponsibility?

When Can You Vary a “Final” Spousal Support Order on an Interim Basis?

 My Spouse Has Bad Credit – What’s My Exposure?

  1. Spending to Feed an Addiction

In a second case, Dillon v. Dillon, 2010 ONSC 5858, the husband was a severe alcoholic, who incurred debts to feed his alcohol addictions. He lost many jobs over the years, and took pains to hide the dire family financial circumstances from the wife, who was completely unaware.

Given that their financial circumstances were spurred by the husband’s need to incur debt to feed his addiction, the court found this was a situation completely out of the wife’s control. Because of his reckless behaviour, she had effectively contributed significantly more than the husband toward amassing their family assets which formed the NFP – for example a cottage worth $260,000, and RRSPs funds amounting to $150,000. She had also paid over $50,000 towards the husband’s debts in order to keep things afloat for the benefit of their children.

By concealing the extent and timing of his “financial perdition” (as the court called it), the husband deprived the wife of an opportunity to prevent his destructive behaviour, or to prepare herself for retirement. The court found that the husband had “taken advantage of the [wife’s] selfless act of placing herself in a position of vulnerability in the best interests of her children.” An unequal division of NFP was ordered.

Learn more:

82 Year-Old Gambling Husband Loses Almost Everything – Should the Wife Get What’s Left?

Leaving lost wages? Court may order an unequal division property.

Should Alcoholic, Unemployed Father Be Forgiven $40,000 in Support Arrears?

  1. Spending Money on an Affair Partner

Finally, in a case called Hutchings v. Hutchings (2001), 2001 CanLII 28130 (ON SC), 20 R.F.L. (5th) 83 (Ont. S.C.J.), the husband was engaged in an extra-marital affair, and used family money in to order to travel with his mistress to Europe and Quebec. The wife was suspicious, and accused the husband of spending money on not just this but other affairs as well; however she was never able to prove the allegations. In this case, the court also ordered that the husband

had engaged in reckless and intentional depletion of the NFP and that there should be an unequal division.

Learn more:

Wife’s Accusations About Husband’s Infidelities “A Waste of Time”

Can a “Misbehaving“ Spouse Lose Out on Support?

If Husband Was Unfaithful, Should Wife Get Bigger Share of Equalization?

 

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 RussellAlexander.com

Dad’s Poverty Claim Foiled by Instagram Pics

fuji camera lens vintage

Dad’s Poverty Claim Foiled by Instagram Pics

The father had been ordered to pay child support in 2009, but never did. Over the course of the following decade, the child support arrears had accumulated to the point where he owed the mother more than $145,000 in respect of their two children.

It was only in 2018 that the matter came back before the courts, when the father asked the court to rule that he had met the tests for reducing the arrears, and for eliminating the going-forward support obligations. By law, this included the court looking at whether there had been a change of circumstances that occurred since the original child support order was made.

The father claimed that he’d had to move out of province to look for work in 2010, and that his income had dropped significantly from the almost $73,000 on which his child support levels had been calculated. In fact, he said he’d earned just over $11,000 in that year, and ended up living on the streets and panhandling for money. He said he also became an alcoholic, and sobered up only in 2012 when he met his former fiancée. However, he claimed that he and the fiancée were no longer in a relationship.

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The court relied on Instagram to both prove – and then disprove – various parts of the father’s story.
First, it accepted the claim that the father met his fiancée in 2012, because Instagram photos were filed with the court showing them together. But other Instagram photos proved to the court that the father was lying when he said the relationship had since ended, and that he was currently living alone in poverty in a basement apartment. The court said:

[The father] says that he is separated from [his fiancée], and that they are co-parenting their child, Nina, who lives with [the fiancée]. [The father] claims to live in relative poverty in a basement apartment costing him $400 per month. …
However, the Instagram photographs filed by [the mother] demonstrates a completely different lifestyle. They disclose a number of trips to Columbia, the most recent of which may have been as late as 2019, as well as trips to Portugal and to France. There are numerous smiling images of [the father and his fiancée] enjoying visits to exotic locations. There was a post from [the fiancée’s] mother which congratulates [the father] for acquiring a residence in Columbia. [The father] flew his daughter, Vanessa, to Columbia for a holiday in 2017. …
[The father] claims … to have paid these trips through points earned by buying gas for company vehicles which he drove when he was working. Outside of the fact that he needed about 300,000 points to go on the trips that [the mother] was able to find out about, that statement does not ring true. [The father] must be driving a lot to earn points to buy flights to Portugal for himself and his daughter, Nina (60,000 points). Yet he claims to effectively be working part-time because of his own health issues, which would mean that he would not be driving very much at all …

This evidence contradicted the father’s claims that he was earning $16 per hour and had an annual income of $17,000 per year; his stated income and lifestyle were simply at odds. The court surmised that it was more likely that he was being paid under-the-table by the fiancée, who owned her own business. When giving evidence they were both vague about the company he worked for and the details of his alleged employment.

Dad Wrests Custody from Mom After She Alienates the Kids from Him

Dad Wrests Custody from Mom After She Alienates the Kids from Him

The parents married in 2007, and had two daughters. In 2016 they separated very acrimoniously, and the court ordered the children to live primarily with the mother pending a later determination of their fuller issues. The father as given generous access on a set schedule.

At that later hearing, the mother asked for joint custody but with the added stipulation that the children would live with their father only on a limited basis, pursuant to a set schedule. In a somewhat unusual move, the father asked the court to change the status quo so that he had sole custody, with an equal timesharing agreement during various set days.

According to the father, the basis for this request was that the mother had used the time since their separation to intentionally alienate the children from him, and to relegate him to a small role in their lives and upbringing.

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The court heard that even during the marriage the father had tried to be actively involved with the children, but that the mother had made all the decisions about their care. In the court’s words, she “attempted to dominate all aspects of the children’s lives and attempted to reduce the [father] to a spectator regarding his own daughters”. This changed only when it suited the mother’s needs, and in the father’s view it only got worse after they split up.

For instance, he claimed that since separation she blocked him from having overnight access, even though he lived with his parents in a five-bedroom home that the family had occupied during the marriage. She suddenly and unilaterally terminated his right to pick up the children from school. She refused to allow him summer access, forced him to go to court three times over that issue – and then did not even show up for one of the court hearings.

The father also accused the mother of thwarting the children’s everyday interactions with him. Since separation, he still encouraged the children to call their mother during every one of his access weekends; conversely, he had received only two calls in the entire time they were with her. The children were also encouraged to keep secrets from the father, and were coached not to eat meals with him on those limited days during the week when he had access. The mother also did not inform the father of any medical, dental or counselling appointments, even though she had been ordered by the court to do so. Finally – and tellingly in the court’s view – she also insisted that the father’s weekend access be interrupted so that she could take the eldest child to piano lessons on Saturday mornings, and to her church on Sunday mornings.

The court found this collectively indicative of the mother’s “selfishness and lack of appreciation of the role that the [father] plays in his own daughters’ lives.”
The court added that both parents clearly loved the children, and both had the requisite parenting skills. But while the father’s overall conduct was geared towards the children’s best interests, the mother’s conduct was not. Joint custody was not appropriate, since the mother had not been willing to cooperate and make joint decisions. As the court explained:

The [mother] does not value and recognize the [father’s] crucial role in the lives of the two children. The [mother] is self-centred and only considers her best interests and not those of her children. Rather than embrace the [father’s] involvement in the children’s lives, the [mother] has attempted to minimize and restrict his involvement in major decisions affecting the girls and in a parenting scheme that is in the girl’s best interests.

The court accordingly ordered that it would be in the children’s best interests that there be shared physical access to the children, but that the father should have sole custody. Although the father was required to consult with the mother prior to making any final decisions, in the event of a dispute, he was granted the right to make the final decision. Otherwise, the children would reside equally with both parents on a stipulated, strict schedule.

For the full text of the decision, see:
Pryce v. Pryce, 2019 ONSC 3558 

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 RussellAlexander.com

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