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New Family Law Rules on Expert Evidence

New Family Law Rules on Expert Evidence

As recently as last week a new set of family law rules relating to evidence have come into force, namely the use of expert reports in cases. More often than not in cases evidence is submitted to the court from an individual claiming to be an “expert”, when in reality these reports are more casual.

The Courts of Justice Act now requires that claims under the Divorce Act or Children’s Law Reform be accompanied by joint litigation experts that may be subject to preliminary review. The rules also list the following requirements for expert reports:

1) Expert’s name;

2) Their area of expertise;

3) The expert’s education and employment history;

4) The nature of the opinion being sought and its relevance to the case at hand;

5) The instructions they were provided; and

6)The expert’s reasoning for their conclusions

The rules in turn are said to provide a much less biased use of experts because parties may not always be permitted to retain another expert of their own if they are displeased with the current one’s opinion. From a monetary perspective, bringing in expert witnesses can be expensive and it may be wise for the parties and counsel to settle the matter themselves. Yet, some cases can be settled much sooner with their participation, thus making their inclusion relevant on a case-by-case basis.

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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

Jet-Setting Dad Won’t Cough Up Credit Card Statements – So Court Declines to Grant His Order

Jet-Setting Dad Won’t Cough Up Credit Card Statements – So Court Declines to Grant His Order

A recent Ontario ruling illustrate a simple point, and one that should be heeded by all Family litigants:  Spouses must make full financial disclosure – even if it could hurt their case.  In a recent case called Brito v. Brito the husband learned this the hard way, in connection with bank and credit card statements that he refused or deliberately neglected to provide.

The husband had been subject to a court order in Ontario, requiring him to pay over $1,000 a month in support retrospective to 2008, based on imputed income of almost $73,000 per year.  However, he never honoured that support order.

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To the contrary, he moved to Alberta, where he persuaded a judge to grant a provisional order reducing his support obligation to $162 a month, based on what he told the court was his current annual income of $17,000.  At that point, he was already $145,000 in arrears under the original Ontario order.

He then retuned before the Ontario court to ask that the more favourable Alberta order be confirmed.

“Not so fast”, the Ontario court essentially said.  The problem was the husband had never made full financial disclosure along the way, as he had been previously ordered to do.   Indeed, the details of his income remained sketchy and suspicious.  The court wrote:

I only have income as to Mr. Brito’s lifestyle, which cannot be supported by the income that he says he makes.  I do not have bank statements or credit card statements which would support his assertion that his income is low and that he lives in relative poverty.  I believe that he has been untruthful about certain fundamental facts, including his evidence that he is no longer living with or partnered with [a new girlfriend] In short, I do not believe that Mr. Brito’s income is as he says it is in his income tax returns, and I do not have any evidentiary basis to make some other income finding in order to find that his income is something else.

In a noteworthy comment, the court noted that the husband “has not provided the disclosure requested as to his credit card or bank statements or as to his personal circumstances, and this in itself may very well warrant a dismissal of the claim to confirm the [Alberta] order.”   The court elaborated:

Moreover, Mr. Brito has not provided the disclosure that [his wife] has requested.  He says that he cannot afford to do so.  [His wife] asked for bank and credit card statements from 2012 to present.  … Mr. Brito has stated that he cannot afford to obtain or provide bank statements prior to January 2017.  He has not provided all of his credit card statements, only those as outlined in his affidavit, of which the earliest is from 2016.  …

Mr. Brito says he cannot afford to obtain documentary disclosure for these proceedings, but he can afford trips to Columbia, Portugal, and France, some of which he has taken since the commencement of his variation claim.  …

Indeed, the court homed in repeatedly on the husband’s lack of disclosure around his credit cards, since these could prove or disprove his claims that he was paying for recent travel while claiming to be impoverished.  It said:

Finally, Mr. Brito was asked to produce his credit card statements.  This was his chance to produce the credit card statements for the points’ card through which he purchased his flights.  He did not.  None of the statements provided appear to be for a travel points card which would have permitted Mr. Brito to buy flights to Portugal, France, and Columbia.

I simply do not believe Mr. Brito when he says that the trips that he has taken were purchased through a points card which reflected his at work gas purchases.  This means that, assuming Mr. Brito is telling the truth when he says his finances are completely separate from those of [his new girlfriend], that he is paying for the trips from his own resources, which remain undisclosed to this court.

In the end, and based partly on this non-disclosure, the court declined to confirm a portion of the prior Alberta order, and went on to make related substantive claims as to the husband’s support obligations to his ex-Wife.

For the full text of the decisions, see:

Brito v. Brito, 2019 ONSC 3526 (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

Who Pays Child Support in Ontario?

Who Pays Child Support in Ontario?

The Details of Ontario Child Support

Child Custody and Access

When parents are going through a separation or divorce, some of the most difficult decisions that need to be made are those concerning the children. Who will the children live with? Who will have custody? What happens if the parents cannot agree?

Legal Aspects of Child Custody and Access

Ontario family law recognizes that children often benefit from having maximum contact with both parents. Where appropriate, parents should share in the parenting decisions related to their children, as well as the time spent with their children.

In some circumstances, parents wish to maintain joint custody and make decisions regarding their children jointly, but decide that it would be in the child’s best interests to have the child live primarily with one parent.

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In these situations, the parent with whom the child does not reside most of the time can foster her or his relationship with the child through “access.” This term simply refers to the time that the other parent will spend with their child.

Where parents can agree on how to split their time with their child or children, this arrangement can be as detailed or as open-ended as the parties agree. For example, parents may wish to outline which holidays are spent with whom in advance, so that the child does not feel any guilt about having to “decide” the issue when it arises.

This can also prevent any dispute as to what is an equitable sharing of the child’s time. Where parents cannot agree on the major decisions involving their children or on how the child’s time should be divided, a court can make an order to provide the parties with a solution.

Different Types of Custody

Shared custody

If each parent has the child at least 40% of the time, the Child Support Guidelines say there is “shared custody.” This refers only to the residential agreement, and should not be confused with the term “joint custody,” which refers to the parents’ joint right to make major decisions for the child. When there is shared custody, the amount of support paid to the parent with custody might be less than the amount set out in the table. Therefore, the term “shared custody” only refers to the amount of time spent with the child.

There is no formula in the Guidelines for determining how much time is spent with each parent in a shared parenting scenario. The onus is on the parent who claims they have shared custody to show that the child is with him or her at least 40% of the time.

If the judge finds that the child spends at least 40% of their time with the parent who pays support, the Guideline table amount will no longer apply. Instead, the judge will look at the gross income of each parent to determine the child support amount, as well as of time the child spends with each parent. This takes into account the reality of a shared parenting arrangement, because the more time the child spends with each parent, the more each parent is expected to provide basic items for the child, such as pajamas, toys, clothes, and bedding. Judges must consider these extra costs when they set support amounts for shared custody.

Split custody

Sometimes when parents with more than one child separate, one or more of the children will live with each parent. When this happens, child support depends on the income of both parents. How much support each parent would owe for any children living with the other parent is figured out according to the Guidelines. The parent who owes the higher amount must pay the difference between the two amounts to the other parent.

Take the example of one parent with custody of two children and an income of $25,000, and the other parent with custody of one child and an income of $45,000. According to the table, the parent with the lower income owes the other parent $211 a month in support for the one child who lives with that other parent. The parent with the higher income owes the other parent $680 a month in support for the other two children. When you subtract $211 from $680, the higher-income parent owes the other parent $469 a month in child support.

Sole custody

When a parent has sole custody of a child, this means that they are solely authorized to make major decisions for the child, to the exclusion of the other parent. In these cases, it makes sense that the child’s primary residence will be with the parent having sole custody. Therefore, to determine how much child support is to be paid, the courts are required to look to the Child Support Guidelines, which outline a table amount that is based on the payor parent’s income. The recipient parent’s income is irrelevant to this determination, as Child Support is the right of the child to receive. In some cases, the recipient parent’s income may be relevant, if there are special or extraordinary expenses to be shared above the Table amount. Since the Table amount is meant to cover only regular day to day expenses, such as food, clothing and shelter, any additional, or extraordinary expenses, are generally shared between both parents, proportionate to their incomes. Some examples of these expenses include daycare, dance lessons, and medical expenses not covered under a medical plan.

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

Husband Ordered to Pay Wife $500 Per Day for His Continued Non-Disclosure

Husband Ordered to Pay Wife $500 Per Day for His Continued Non-Disclosure

In the four years since the husband and wife embarked on their family litigation, the wife had obtained five separate orders to try to compel the husband to make full financial disclosure, as he was legally required to do.  None of those netted the desire result in full; there were still many outstanding items, including the husband’s bank account statements, pension information, updated trading account statements, and credit card statements.

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Forced to bring the matter before the court yet again, the wife requested another order compelling disclosure. This time, however, she asked for more severe sanctions:  If he did not comply, the husband should either have his pleadings struck out entirely, or else he should face a daily $500 penalty for each day of non-compliance.

The morning of the hearing, the husband did come up with some of the missing materials. However, the court declared this a waste of its time, because the wife’s lawyer had to take time to review the documents. The husband had also provided 150 pages recently, but much of it turned out to be a duplication of material he had submitted earlier.

Nonetheless – and despite the husband’s history of non-cooperation – the court credited him for at least making some recent efforts. The court declared that it was “prepared to give the husband one last chance to provide the outstanding disclosure on strict terms.”  It listed the specific items that he was being ordered to provide, and cautioned that they should be arranged in an “organized fashion”, without duplication, and that certain ones were to be given in “chronological order”.

As for the requested sanction, the court homed in on the wife’s suggestion that the husband be subjected to a daily monetary penalty if he did not comply.  Admittedly, such a penalty was to be reserved for exceptional or egregious circumstances; however in this case the husband had been given numerous opportunities – over a span of years – to comply with his financial disclosure duty.  The court said:

The wife states that another court order alone will not compel the husband to provide the documents. Five other orders have already been made, he has paid the associated costs and yet he has not complied with them.  All of this shows that he believes he can disregard court orders.  

The court added that the husband was savvy and has the financial wherewithal to litigate:  His TD investment account had increased by almost $1,200,000 in the span of a year.  The court surmised that a financial penalty was something that might have an impact on his willingness to cooperate, and that he would likely not do so unless such a monetary sanction was imposed. The court said:

This is the sixth court order requiring disclosure.  Given the husband’s litigation history, I agree with the wife that the prospect of compliance with this order is very poor unless stiff consequences are imposed.  These circumstances are exceptional and egregious.

The court set a deadline for the husband’s disclosure, and stipulated that if he failed to comply, he was ordered to pay a daily fine directly to the wife of $500 per day for each day of non-compliance.

For the full text of the decision, see:

Florovski v. Florovski, 2019 ONSC 5013 (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

Wednesday’s Video Clip: Can an Ontario Support Agreement or Order be Changed?

Wednesday’s Video Clip: Can an Ontario Support Agreement or Order be Changed? 

 

At Russell Alexander Collaborative 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

Mother-In-Law’s Meddling Impacts Wife’s Spousal Support Entitlement

Mother-In-Law’s Meddling Impacts Wife’s Spousal Support Entitlement

The couple, who were practicing Muslims, underwent an arranged religious marriage ceremony in 1997, and a legal marriage in 2000.   Their 2012 separation, which the court described as “difficult”, included an incident in which the husband assaulted the wife.  They launched their family litigation to have the court sort out their various disputes.

On the eve of trial, the spouses managed to settle on a joint custody arrangement for their two teenaged children, who would continue to live with the mother.  This left only a handful of financial issues still to be resolved by the court; these included equalization, spousal support, and retroactive support.

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However, when it came time to give evidence on these, the spouses had difficulty in maintaining their focus. As the court put it:

Notwithstanding the financial nature of these issues, both parties spent much of their energy at trial testifying about the children and the way the other treated them during the marriage and separation.  Mr. Vhora concentrated on how he was unjustly charged with assault and about his loss of his relationship with the children; Ms. Vhora spoke about the abuse she suffered at the hands of the [husband’s] mother during marriage, and how the [husband] had failed to honour her wishes for a separate residence for the parties and the children.  Both parties testified at length about the assault.

None of this was particularly relevant to the financial issues, but it used up valuable trial time. This left little opportunity for testimony about the details that were crucial in determining the financial issues.

The case was also muddied by certain allegations against the husband’s mother.  Although she had participated in setting up the arranged marriage involving her son, things did not go well after-the-fact.  The court explained:

Immediately after the religious ceremony, the parties moved into the home of Mr. Vhora’s parents … According to Ms. Vhora, the [husband’s] unwillingness to move out of his parents’ home, along with Ms. Vhora’s toxic relationship with the [husband’s] mother, Zarin Vhora, eventually resulted in the breakdown of the marriage. …

Ms. Vhora could not initially work in Canada when she was married in 1997, as she was here on a visitor’s permit.  Ms. Vhora said that she was only able to become a permanent resident with the consent of her mother-in-law.  She testified that Mr. Vhora’s mother did not initially want her to work or to obtain permanent status in Canada because she wanted to retain the power to threaten to return Ms. Vhora to India if she misbehaved.  …

The court also recounted the evidence of interference by the husband’s mother, which in the wife’s view was tantamount to abuse – but which the husband denied outright:

The Role of [the Mother-in-Law] Zarin Vhora

According to Ms. Vhora, she was subjected to continual and ongoing abuse at the hands of her mother-in-law, Zarin Vhora.  She testified that Zarin Vhora made ongoing attempts to intimidate and control her.  Ms. Vhora described herself as nothing other than a servant to her mother-in-law, and at one point says that she listed all of the jobs that she was doing in the home in an attempt to obtain fair treatment. Ms. Vhora said that Zarin Vhora controlled the household, and when she asked to work outside of the home, it was Zarin Vhora who decided whether she could or not.  Whenever Ms. Vhora stood up to her mother-in-law, she would threaten to send her back to India.  Ms. Vhora said that Zarin pulled her hair once, and on another occasion said that if she were in India, she would “peel the skin from [Reshma Vhora’s] body.”  Ms. Vhora gave evidence that Zarin called her a “fat black ass” and often asked Mr. Vhora why she had married her.  Zarin Vhora was not questioned about these allegations of abuse when she testified.

Ms. Vhora complained that her husband stood by passively, and went along with his mother’s demands.  She also testified that her husband assaulted her by striking her a week prior to separation because his mother invited him to do so.  Ms. Vhora blames Zarin Vhora for the abuse visited upon her by her husband.  She said that after separation, she had sent Mr. Vhora a list of demands prior to any possible reconciliation. One of those demands was a place of their own.  Ms. Vhora maintained throughout her testimony that Zarin Vhora, not Mr. Vhora, was the source of the problems in their marriage.

After chronicling some of these accusations, the court pointed out that the trial was actually about financial issues; the determination of whether the wife’s mother-in-law was abusive was not part of the court’s task-at-hand.  Still, it was useful information for enlightening the court on the extent to which the wife was involved in the financial decisions made within the family, and by extrapolation the extent to which she was entitled to spousal support:

Relevant to this is the way in which Mr. and Ms. Vhora managed their money.  Ms. Vhora had to hand over her entire paycheque to her husband every two weeks, other than a $100 allowance for personal needs.  Ms. Vhora was also asked to account for her expenditures when she wished to go to India and requested some funds to do so.  It was apparent that Ms. Vhora had little financial autonomy within this particular household.

There is no question that this marriage was an extremely traditional marriage.  Ms. Vhora had little economic power within the marriage, and was under the financial control of her husband and his family.  There are four examples which prove this to be the case:

  •      Ms. Vhora was forced to hand over all of her paycheques to her husband other than a $100 “allowance” for personal expenses;
  •      Ms. Vhora both worked outside the home and was responsible for many domestic chores within the home, as exemplified by a list of jobs prepared in a negotiation to reduce her work load;
  •      Ms. Vhora was kept in the dark about the purchase of the Germain Crescent home;
  •      Ms. Vhora was forced to resign from her job by her husband and his mother;

The most blatant example is the fact that Ms. Vhora was forced to hand over her entire bi-weekly paycheque to her husband apart from a $100 “allowance” for her personal needs.  Ms. Vhora says that when she began to work … she was only able to do so with the permission of her husband.  She said that her husband allowed her to work only on condition that she gave him her entire paycheque when it was deposited into her account.  She said that the amount she was permitted to spend on herself was $100 per paycheque, which was increased later in the marriage to $200 per paycheque. … Other than the “allowance” permitted to her by Mr. Vhora, the money she made was viewed by Mr. Vhora and his mother as the family’s money and was withdrawn by Mr. Vhora from the joint account that the parties had together. …

If the goal was for Ms. Vhora to save money [as the husband claimed], it failed. The [wife] was left with little or no savings when she left the marriage in January 2012, while Mr. Vhora had significant savings.

In the end, the court took the overall family atmosphere – and the mother-in-law’s dominance and meddling – into account when making its rulings in the wife’s favour, on the remaining issues of equalization, spousal support, and retroactive support.

For the full text of the decision, see:

Vhora v. Vhora, 2016 ONSC 2951 (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 to 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 conclude 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 to 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 

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

Bigamy

Bigamy

In a Blog a few months ago we chronicled the legal woes of a much-married man named Errol.

It seems Errol was quite good at getting married – he had undergone three successive marriage ceremonies with three different women – but he was not-so-good at first making sure he was legally divorced before walking down the aisle each time.  This became an issue when some of his many wives came after him for spousal support under Ontario family law, and it meant that the court had to untangle the legal effect of his various marriages and the impact of each on the successive one, to determine whether they were valid, invalid, or subject to being annulled (as the case may be).

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In the course of sorting out Error’s matrimonial predicament, one of the side-issues that came up in the court’s discussion was whether he might have committed bigamy, which is actually a criminal offence under s. 290(1) of the Canadian Criminal Code.

Under the wording of that provision, a conviction for bigamy can carry a sentence of up to five years’ imprisonment, and occurs any time:

  • A married person goes through a form of marriage with another person;
  • Any person, knowing that another person is married, goes through a form of marriage in Canada with that person;
  • Any person goes through a form of marriage with more than one person on the same day or simultaneously.

(And note that these situations must occur in Canada; however a person can also be covered by the bigamy definition if he or she is a Canadian citizen and resident in Canada, but leaves with the intent to engage in the prohibited conduct and carries out the intent to do so).

Arguably, Errol was in jeopardy of being found guilty of bigamy if it was found that he was already married, but then got married again without ending his first (or second) marriage in the proper legal manner (which might be divorce or an annulment, depending on the circumstances).  Likewise, if any of the Errol’s wives married him knowing that he was already married to someone else, they might be guilty of the crime of bigamy as well.

All of this was potentially pertinent to Errol’s many matrimonial misadventures, since the validity of his latest marriage for Family Law purposes was partly contingent on whether he was already married to someone else at the time of the ceremony.  The possibly that Errol knowingly committed bigamy was part of the larger picture that the court considered.

Indeed, on the Family Law aspect the court readily found that Errol had been less-than-forthright about his matrimonial history, not only to his many wives but also to the court itself.  The court wrote:

Findings of bad faith

 Mr. Lowe was not forthcoming in his testimony. The court therefore found it challenging to acquire thorough and complete evidence from him. He omitted information about his first marriage and divorce from his initial testimony. That history only became apparent on further questioning by the court based on the documentary evidence.

The court notes that Mr. Lowe acknowledged he was aware that he was not in compliance with Canadian law when entering into both his second and third marriages. This constitutes bad faith by the definitions in [Canadian family law]. I find, however, that his third wife, Ms. A.A. was not aware of any lack of compliance with the law by Mr. Lowe. She entered into the marriage in good faith, believing that the marriage was properly constituted.

As such, that third wife’s good-faith marriage to Errol was eligible to end in divorce (and that his marriage to the second wife was void from the outset).   The court did not provide an opinion in whether Errol was a bigamist – since that is a separate determination for the criminal courts – but it would not be a surprise if Errol found himself before those courts soon enough.

For the full text of the decision, see:

Lowe v. A.A., 2018 ONSC 3509 (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

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