I have met and heard the tragic stories of many parents. PA is a function, by and large, of a custodial ex-partner, although some alienation can start while the couple is still together.

This blog is a story of experiences and observations of dysfunctional Family Law (FLAW), an arena pitting parent against parent, with children as the prize. Due to the gender bias in Family Law, that I have observed, this Blog has evolved from a focus solely on PA to one of the broader Family/Children's Rights area and the impact of Feminist mythology on Canadian Jurisprudence and the Divorce Industry.

Friday, June 27, 2008

Northwest Territories passes motion in support of equal parenting

Northwest Territories passes motion in support of equal parenting and Vellacott’s Motion M-483

For Immediate Release June 27, 2008

OTTAWA The Northwest Territories has demonstrated its pioneering spirit by paving the way for equal parenting in Canada. Guided by the leadership of Kam Lake MLA David Ramsay, the Legislature of the Northwest Territories, on June 19, passed a motion to affirm the importance of "equal parenting" as in the best interests of children even in cases of marriage breakup and family dissolution. This guiding principle of course recognizes exceptions in cases of proven child abuse or neglect. In speaking to his motion, Ramsay said, "I believe strongly that both parents should be involved in the upbringing of a child. If you look around the world, the movement is going to a default system of equal, shared parenting so that both parents in separation and divorce have equal access to children."

The motion passed unanimously with a vote of 11 to zero, with seven abstentions. The Cabinet abstained, but Ramsay, noting that they did not vote against the motion, is confident that, with further study, they will come down strongly in favour of equal shared parenting.

Ramsay's motion was introduced as an expression of support for an equal parenting motion introduced in the Parliament of Canada by Saskatoon-Wanuskewin MP Maurice Vellacott. Vellacott tabled Private Member's Motion M-483 earlier this year and it is scheduled for its first hour of debate this fall. Ramsay said, "I’m waiting anxiously for this vote to take place and debate to take place in the House of Commons in Ottawa this fall. I would look to Members of this House to lend our support to the government in Ottawa to open up the federal Divorce Act and make amendments to it so that we do have a default to equal, shared parenting in this country, and we get with the program of respecting the rights of everybody." Ramsay added: "Mr. Maurice Vellacott, MP from Saskatoon–Wanuskewin, is the MP in Ottawa that is spearheading an effort to open up the federal Divorce Act so that we can see a move towards equal and shared parenting."

In this fall's debate, Vellacott is looking forward to making the case for the importance of both fathers and mothers taking an active role in the lives of their children, regardless of the nature of the relationship between the parents themselves. "The social science is air-tight on the importance of fathers and mothers if children are to be prepared in their early years for the best outcomes in the whole range of life experience as they grow older," Vellacott said. "I want to thank the MPs from different parties who have publicly expressed their support for this motion by putting down their names as Seconders of the initiative," he added.

M-483 reads: "That, in the opinion of the House, the government should propose amendments to the Divorce Act so that law and practice ensure due process protection of rights and equality of parents, and to ensure that children benefit from equal parenting from both their mother and their father, after separation or divorce."

The motion passed in the Northwest Territories' Legislature reads as follows:

"WHEREAS it is in the best interest of the child to have, wherever possible, both parents involved in the parenting of said child;

"AND WHEREAS the current adversarial process pitting parent against parent with the child in the middle is promoted in legislation like the federal Divorce Act;

"AND WHEREAS it would be desirous for the federal government to propose amendments to the federal Divorce Act so that in law and in practice the rights of both parents to due process are observed in all proceedings and that children benefit from equal parenting from their mothers and their fathers after separation or divorce;

"NOW THEREFORE I move, seconded by the honourable Member for Great Slave, that this Assembly signify their support for amendments to the federal Divorce Act to protect the rights of both parents to be involved in parenting the children;

"AND FURTHER that the content and result of these proceedings be forwarded to the federal Minister of Justice and the Member of Parliament for Western Arctic for their consideration."

"I want to thank Northwest Territories MLA David Ramsay for his leadership on this issue of equal parenting," said Vellacott. "Support for equal parenting is a vote for children, a vote for the equally necessary role of moms and dads, and a vote for the principle of equality," Vellacott added.

- 30 -

For more information, contact Maurice Vellacott at (613) 992-1966, (613) 297-2249 or Vellacott.M@parl.gc.ca

and contact David Ramsay at (867) 669-2296 or at david_ramsay@gov.nt.ca.

Monday, June 23, 2008

Update on Canadian Parliamentry Motion M-483 Equal Parenting


Dear Mike:

I'm writing on behalf of the CEPC coalition organizations and membership to thank you for the time and effort invested in advocating for M-483 Private Members Motion (PMM).

As a result of the strong response from the Family Rights Movement and its friends, Mr. Vellacott placed "Equal Parenting" over other competing business on the Order Paper. Moreover, our concerted advocacy campaign has signed up 15 Seconders for the PMM as of this writing. Our target is the 20 maximum allowed Seconders with all-party representation in order to demonstrate that this in a non-partisan issue of importance to all Canadians.

Our work is has just begun as you well understand. Specifically, we need to campaign throughout the summer to ensure we have mustered enough MPs for a majority vote when the motion is brought up for First Reading in early autumn (barring any election call). We're asking you to meet with MPs from all parties in your surrounding ridings to promote M-483, and have attached brochures for this purpose.

MPs meet with their constituents and other interested parties in their riding offices during the summer. The constituency telephone number to make an appointment can be found here.

The key questions to put to the MP are:

  • Does the MP support Equal Parenting in principle?
  • Is the MP willing to second the motion? If so , {insert process here}
  • If not willing to second, will MP vote in support of M-483?
  • If the MP is undecided or uncertain, what additional information would he like?
  • If the MP is opposed, on what grounds?

CEPC is maintaining a master MP Support list to track the vote count. At the present time we need 25 more MPs to indicate their support for M-483. Please forward the results of your meeting to one of the following:

We will then update our master MP tracking Spreadsheet with your results , and also endeavour to provide you with additional information requested by the MP.

United in Purpose and Spirit,

George Piskor

VP-Policy & Planning

Canadian Equal Parenting Council/ Conseil pour l'Équité Parentale du Canada

(905) 380-4310 phone gwpiskor@nospamsympatico.ca


Encl: Brochures


Organization Head Office Location Contact Email Web Site

(ANCQ)Action des Nouvelles Conjointes et Nouveaux Conjoints du Québec Quebec ancq1999@videotron.ca www.ancq.qc.ca

Alex Alert Network jerrydante@yahoo.ca alexalert.webs.com

Amnesty-4-Families info@amnesty-4-families.org

CCEP (Canadian Coalition For Equal Parenting) Regina brianleejohnson@accesscomm.ca

Children's Rights Council of Canada bjenkins@axxent.ca

Commoners' Publishing Inc. Ottawa commoners@rogers.com www.commonerspublishing.com

Dads of Durham Oshawa pat.andrus@jhsdurham.on.ca

Dads_In_Action Ottawa http://groups.yahoo.com/group/Dads_In_Action/

Divorce Radio Project Calgary info@divorcecalgary.com

ECMAS (Equitable Child Maintenance & Access Society) Edmonton gandjhomedad@hotmail.com www.ecmas.org

EPGS( Equal Parent Group Society) DWMillar@Rogers.com www.equalparenting-bc.ca

Equal Parening of Canada (EPOC) Ottawa cheriton@rogers.com http://groups.yahoo.com/group/EPOC_NEWS/

Equal Parenting of Durham Bowmanville uncledad57@gmail.com

Everyman.org Ottawa unittj@cyberus.ca everyman.org

F4J Fathers 4 Justice (Canada) New Westminister office@fathers-4-justice-canada.ca www.fathers-4-justice-canada.ca

Families 4 Justice.ca Surrey office@F4J.ca www.F4J.ca

Families For Fathers Toronto jennifer.allison@rogers.com

Family of Men Support Society Calgary earl.silverman@familyofmen.com www.familyofmen.org

FatherCraft Canada Ottawa fathercraft@rogers.com

Fathers Are Capable Too: Parenting Assoc. Toronto president@fact.on.ca www.fact.on.ca

Fathers For Justice -Quebec Montreal benoit@carbanzo.com montreal@fathers-4-justice.ca

fathers-4-justice-NWT Yellowknife bogan98@yahoo.com www.fathers-4-justice-canada.ca

Fondation Gilbert Claes Quebec gilbert.claes@oricom.ca

Glad to be a guy Montreal pageau_ceg@yahoo.ca garscontent.com

Keeping Families Connected Tigard rick@keepingfamiliesconnected.org www.keepingfamiliesconnected.org

L'Apres Rupture jeanpierre.gagnon@sympatico.ca www.lapresrupture.qc.ca/

Men's Rights, Inc. Sacramento mrinc@att.net

Nanaimo Men's Resource Centre Nanaimo theo@nanaimomen.com www.nanaimomen.com

New Brunswick Children's Equal Parenting Assoc. Saint John er_hoyt@msn.com

Ottawa Men's Centre Ottawa www.OttawaMensCentre.com

papapourtoujours,les enfants d'abord Rimouski P. papa-pour-toujours@live.ca

Parents' Coalition of British Columbia New Westminster theo@parentswhocare.ca www.parentswhocare.ca

Politically Active Dads Toronto waynecook@rogers.com

Shared Parenting Works shared.parenting.works@gmail.com http://sharedparentingworks.org/

Windsor Men's Forum Amherstberg bobmcguire971@yahoo.ca


M-483 has grown to 15 Seconders as of parliamentary summer recess.

No. 22

M-483 — April 11, 2008 — Mr. Vellacott (Saskatoon—Wanuskewin) — That, in the opinion of the House, the government should propose amendments to the Divorce Act so that law and practice ensure due process protection of rights and equality of parents, and to ensure that children benefit from equal parenting from both their mother and their father, after separation or divorce.

Pursuant to Standing Order 86(3), jointly seconded by:

Mrs. Skelton (Saskatoon—Rosetown—Biggar) — May 8, 2008

Mr. Wappel (Scarborough Southwest) — May 9, 2008

Mr. Benoit (Vegreville—Wainwright) and Mr. Hiebert (South Surrey—White Rock—Cloverdale) — May 14, 2008

Mr. Hanger (Calgary Northeast) — May 15, 2008

Mr. Cummins (Delta—Richmond East) — May 20, 2008

Mr. Brown (Barrie) — May 21, 2008

Mr. Breitkreuz (Yorkton—Melville) — May 28, 2008

Mr. Van Kesteren (Chatham-Kent—Essex) — June 4, 2008

Mrs. Hinton (Kamloops—Thompson—Cariboo)— June 5, 2008

Mr. Albrecht (Kitchener—Conestoga) — June 9, 2008

Ms. Folco (Laval—Les Îles) — June 10, 2008

Mr. Anderson (Cypress Hills—Grasslands) — June 11, 2008

Mr. Goldring (Edmonton East) and Mr. Shipley (Lambton—Kent—Middlesex) — June 13, 2008

Motion may not be moved, pursuant to Standing Order 91.1(1).

During the interim you have either received additional letters of support from other coalition members, or have had the opportunity to speak with them directly. It is our understanding that you personally support Equal Parenting, and we hope your support will be expressed as a Seconder to the motion. House of Commons procedures require you to submit a signed letter to the Journals Branch at 140 North, Centre Block, which simply says: "Please put my name down as Jointly Seconding Motion M-483."

If your intent is to instead vote your support, we would appreciate if you would communicate this to either Mr. Vellacott directly (Vellacott.M@parl.gc.ca , (613) 992-1899) or to me, so that we may monitor the level of support.

We enclose Equal Parenting brochures prepared by our member coalition organizations. The case for Equal Parenting is straightforward: When parents divorce, children are not divorced. Children and parents are entitled -as they have been for millennia- to an ongoing relationship with both parents. It is better for children, for parents, and for society.

If the attached brochures do not address issues you may have, including any issues related to party policy, we would be pleased to follow up on your specific items.

Should it be the case that you do not support M-483, we would appreciate being made aware of your specific concerns, as we can then research reasonable solutions. Once again, we believe this is an all-party issue, and in keeping with Canadian traditions, a compromise exists.

Canadian Equal Parenting Council is a national coalition of 35 organizations representing 9,100 members of the extended divorce community- single fathers/mothers, children, grandparents, step-parents, and second spouses numbering 10 million Canadians in total.

Thank you for your support on this initiative,

George Piskor

VP-Policy & Planning

Canadian Equal Parenting Council/ Conseil pour l'Équité Parentale du Canada

(905) 380-4310 phone  gwpiskor@nospamsympatico.ca


What is Equal parenting? Equal parenting is the presumption that parents should share the responsibilities and time of parenting on the basis of equal rights. Of course, parents may agree to divide duties – who drives the kids to soccer, who cooks certain days, who helps with certain homework – but if they can't agree, such as in a highly-conflicted divorce, both parents keep equal rights and responsibilities, unless one or both parents is clearly shown to be unfit.

Why do Parents need rights? Parents need rights because it is the only way to protect the rights of their children. Parents need rights to seek and approve educational and medical services for their kids, to get medical and educational records. Parents without rights have no standing in courts or in government or social service agencies. As minors, children have no standing in courts so parents must represent their rights. Parents without rights mean children without parents and kids without rights.

Why do parents need equality? Both parents need to be equal in rights to be equally respected and to fulfill equal responsibilities. While no one pretends that all parents provide exactly the same parenting time to their children, or exactly the same financial support, both need equal respect from the law, social services and in support programmes. Equality and respect is the best way to ensure that both parents are involved in kids' lives, especially after a separation.

Why do kids need both parents? Kids benefit from healthy male and female role models. They benefit from knowing their parents, grandparents and extended family, from the cultural, religious and moral values they teach. Parents are long-term, unpaid care-givers, a model for caring for others. The relationship between the mother and father is important also, for showing how to resolve arguments and conflicts. It is the model for future relationships. Research shows that kids who grow up without fathers have higher rates of educational, social and health problems. They are at higher risk of addictions, teenage pregnancy and suicide. A village is not a substitute for parents and government cannot parent. Less research has been done on motherlessness, but generally researchers believe mothers are at least equally important.

What is the movement for Equal Parenting? This movement, largely of parents and grandparents, seeks social change at three levels:

1. Reform of family law, court procedures and practice

2. Support for parents, particularly those suffering separation or divorce.

3. Education of the public and parents on why both kids need both parents and why equal parenting makes sense.

Why do parents need support? Divorce is the most stressful event that most people ever go through. It is a time when parents are emotionally fragile and must make important decisions, although vulnerable and upset. Professionals should educate parents and help both stay connected to kids, but sometimes they can view their job as deciding which parent is the "best" parent and exploiting the financial or emotional weakness of one parent to remove a parent from kids' lives. Parents may need support to get emotionally back in balance, to avoid being exploited by divorce professionals, to understand the divorce system and the effects on their children. In legal terms this may mean inserting the "rebuttable presumption" of joint custody in the Divorce act, and recognize that both parents keep rights & responsibilities after divorce.

For further information: Canadian Council for Co-parenting, www.coparent.ca 613.260.2659 c/o 631 Tubman, Ottawa, K1V 8L6 fax 613.260.0401

Briefing Note about: M-483 Private Member's Motion

"That, in the opinion of the House, the government should propose amendments to the Divorce Act so that law and practice ensure due process protection of rights and equality of parents, and to ensure that children benefit from equal parenting from both their mother and their father, after separation or divorce."

This motion, if it passes, will not change the law in Canada, but it will reflect the will of Parliament to fix the way the current system handles custody and access with separating parents.

Benefits of Equal Parenting (EP) in the Divorce Act:

  • Parenting by both parents reduces child poverty
  • EP reduces social problems: youth delinquency, school dropouts, teenage pregnancy, physical and mental health problems
  • EP reduces conflict and likelihood of conflict escalating to violence
  • EP increases grandparent involvement and transmission of healthy culture in at-risk populations
  • EP reduces costs to parents in legal fees
  • EP reduces court, policing and welfare costs to governments
  • EP follows recommendations of the Joint-Senate Commons Committee on Child Custody and Access and adds:

- due process protection - recognition of a balance of rights and responsibilities - recognition of equality of parents


Sign a letter addressed to the Journals Branch of the House of Commons at 140 North, Centre Block, which states: "Please put my name down as Jointly Seconding Motion M-483"

Support the motion by voting for it when it comes to a vote.

For further information: Canadian Council for Co-parenting, www.coparent.ca 613.260.2659 c/o 631 Tubman, Ottawa, K1V 8L6 fax 613.260.0401

Wednesday, June 18, 2008

Exposing deadbeat judges

Barbara Kay

Barbara Kay

posted on Wednesday, June 18, 2008 Bio/Email | Barbara Kay Archives | Printer-Friendly Version

I once sued a horse dealer for fraud. The evidence in hand was irrefutable, so justice-wise the case was a lock. Nevertheless, my world-weary lawyer, familiar with the presiding judge’s record, told me I would likely torpedo my case on the witness stand. Stung, I protested I was truthful and knew my case backwards.

Precisely, he replied. This judge is a small town guy. You’re too urban and obviously competent and articulate for his comfort. He’ll assume you could have looked out for your interests. The defendant will play up her humble rural working life (she did) and he’ll be sympathetic to her.

It was as he predicted, and I lost on a meaningless legal technicality.

One lesson of many I took from this misadventure—the main one being that justice and judgments are two separate animals --is that although a judge must be knowledgeable in the law, he may also be a social idiot, with zero interest or ability in reading human behaviour, as well as blind to his own bias (the furious blushes that accompanied my opponent’s lies, so outrageous they drew spontaneous gasps of incredulity from onlookers familiar with the facts, were ignored).

My case only involved money. Rewind my little vignette and play it out in family court where the right to parent one’s own children is at stake. In 90% of disputed custody cases mothers walk away with “primary care” (in effect sole custody) of their children because, deservedly or not, judges feel sorry for them and find—not a reason, which I learned by experience they don’t actually need—a technical or legal opening to issue the judgment they have already made in their hearts.

The introduction to a book presently nearing completion called Deadbeat Judges: How Courts Disenfranchise Fathers, outlines the triple cause of the syndrome. In the absence of constitutional protection of parental rights, and masking their power-grab under the guise of “best interests of the child,” courts have usurped disputatious parents’ natural right to equal guardianship of their children. Add to that judges’ superannuated impulse toward chivalry for the perceived underdog—virtually always the mother in their eyes—bolstered by a legal culture dominated by third-wave, anti-father feminism.

The result is a perfect storm favouring judicial activism for mothers: “Our Lords and Ladies reflexively defer to women in court, especially mothers. Motherhood is sacred; the role of our noble knights in shining armor on the Bench is to protect it at almost any cost.”

I hasten to add that the eloquent author of Deadbeat Judges, Grant Brown, is particularly qualified to write this expose because, unlike the usual run of fathers’ rights book authors, he has no personal axe to grind. He has never married and has no children, so cannot be called a “bitter loser,” the usual fallback position of unsympathetic critics challenged by former litigants’ unpalatable truths about the family law system.

Brown’s indignation springs from his education in philosophy and ethics, and his experience as a family law lawyer, a profession he has recently abandoned because of the entire divorce industry’s inherent gender iniquities.

Brown has seen it all: judges who aren’t up to date on the facts of domestic violence, and so base rulings on myths and stereotypes; a “disconcerting proportion” of judges who don’t know the law they are supposed to be applying or don’t care to apply it when they do know; judges who ignore evidence, affidavits and expert testimony that favour the father; judges who defer “difficult” (i. e., mother-unfriendly) decisions until it is too late; judges swift to punish fathers for support payment lapses, but loath to impose consequences on mothers who flout access orders.

The six case histories Brown de-constructs are his own, therefore factually reliable, and they will make the blood of any fair-minded reader boil. But while the names of the disputants are altered to protect the children, the actual identities of the case judges are revealed. Since it is well nigh impossible to expose judges’ negligence and unprofessional conduct in any other democratic way, it is time, Brown feels, that demonstrably biased judges face accountability in the court of public opinion.

And public opinion, wherever it is concerned with real gender equity and the right of children to love and be loved by both their parents (in the absence of abuse), will find in these pages a damning indictment of Canada’s family law system.



Tuesday, June 17, 2008

Court Rulings North America and International Relevant to Parental Alienation

Court Rulings North America and International Relevant to Parental Alienation (Document last updated 05/18/08: 78 items)



  • Berry v. Berry, Circuit Court of Tuscaloosa County, AL, Case No. DR-96-761.01. Jan 06, 2001


  • Pearson v. Pearson, Sup Ct. of AK., No. S-8973, No. 5297, 5 P.3d 239; 2000 Alas. Lexis 69. July 7, 2000.


  • Chambers v. Chambers, Ct of App of AR, Div 2; 2000 Ark App. LEXIS 476, June 21, 2000.


  • Coursey v. Superior Court (Coursey), 194 Cal.App.3d 147,239 Cal.Rptr. 365 (Cal.App. 3 Dist., Aug 18, 1987.
  • John W. v. Phillip W., 41 Cal.App.4th 961, 48 Cal.Rptr.2d 899; 1996.
  • Valerie Edlund v. Gregory Hales, 66 Cal. App 4th 1454; 78 Cal. Rptr. 2d 671.


  • Oosterhaus v. Short, District Court, County of Boulder (CO), Case No. 85DR1737-Div III.


  • Case v. Richardson, 1996 WL 434281 (Conn. Super.,Jul 16, 1996).
  • Metza v. Metza, Sup. Court of Connecticut, Jud. Dist. of Fairfield, at Bridgeport, 1998 Conn. Super. Lexis 2727 (1998).


  • Schutz v. Schutz, 522 So. 2d 874 (Fla. 3rd Dist. Ct. App. 1988).
  • Blosser v. Blosser, 707 So. 2d 778; 1998 Fla. App. Case No. 96-03534.
  • Tucker v. Greenberg, 674 So. 2d 807 (Fla. 5th DCA 1996).
  • Berg-Perlow v. Perlow, 15th Circuit Court, Palm Beach County, Fl.,Case no. CD98-1285-FC. Mar 15, 2000.
    • An exceptionally strong family court decision in which five experts testified to the diagnosis of PAS.
  • Loten v. Ryan, 15th Circuit Court, Palm Beach County, FL., Case No. CD 93-6567 FA. Dec 11,2000.
  • Kilgore v. Boyd, 13th Circuit Court, Hillsborough County, FL., Case No. 94-7573, 733 So. 2d 546 (Fla. 2d DCA 2000) Jan 30, 2001.
    • Boyd v. Kilgore, 773 So. 2d 546 (Fla. 3d DCA 2000) (Prohibition Denied)
    • Court ruling that the Parental Alienation Syndrome has gained general acceptance in the scientific community and thereby satisfies Frye Test criteria for admissibility.
  • McDonald v. McDonald, 9th Judicial Circuit Court, Orange County, FL. Case No. D-R90-11079, Feb 20, 1001.
  • Blackshear v. Blackshear, Hillsborough County, FL 13th Jud. Circuit: 95-08436.


  • In re Violetta 210 III.App.3d 521, 568 N.E2d 1345, 154 III.Dec. 896(Ill.App. I Dist Mar 07, 1991).
  • In re Marriage of Divelbiss v. Divelbiss, No. 2-98-0999 2nd District, Ill.(Appeal from Circ Crt of Du Page Cty No. 93-D-559) Oct 22, 1999.
  • Tetzlaff v. Tetzlaff, Civil Court of Cook County, Il., Domestic Relations Division, Cause No. 97D 2127, Mar 20, 2000.
  • Bates v. Bates 18th Judicial Circuit, Dupage County, IL Case No. 99D958, Jan 17, 2002.
    • Court ruling that the Parental Alienation Syndrome has gained general acceptance in the scientific community and thereby satisfies Frye Test criteria for admissibility.[excerpt]


  • White v. White, 1995 (Indiana Court of Appeals) 655 N.E.2d 523. (Ind. App., Aug 31, 1995).


  • In re Marriage of Rosenfeld, 524 NW 2d 212, 214 (Iowa app, 1994).


  • Wilkins v Wilkins, Family Court, Parish of East Baton Rouge, La., Civ. No. 90792. Nov. 2, 2000.
  • White v Kimrey, Court of Appeal, Second Circuit, LA, No. 37,408-CA. May 14, 2003.Click here for the Court's decision.


  • Spencley v. Spencley, 2000 WL 33519710 (Mich App).


  • Truax v. Truax, 110 Nev. 437, 874 P. 2d 10 (Nev., May 19, 1994).

New Hampshire

  • Lubkin v. Lubkin, 92-M-46LD Hillsborough County, NH. (Southern District, Sept. 5, 1996).

New Jersey

  • Lemarie v. Oliphant, Docket No. FM-15-397-94, (Sup Crt NJ, Ocean Cty:Fam Part-Chancery Div) Dec. 11, 2002.

New York

  • Rosen v. Edwards (1990) Tolbert, J. (1990), AR v. SE. New York Law Journal, December 11:27-28. The December 11, 1990 issue of The New York Law Journal [pages 27-28] reprinted, in toto, the ruling of Hon. J. Tolbert of the Westchester Family Court in Westchester Co.
  • Karen B v. Clyde M., Family Court of New York, Fulton County, 151 Misc. 2d 794; 574 N.Y. 2d 267, 1991.
  • Krebsbach v. Gallagher, Supreme Court, App. Div., 181 A.D.2d 363; 587 N.Y.S. 2d 346, (1992).
  • Karen PP. v. Clyde QC. Sup Ct of NY, App Div, 3rd Dept. 197 A.D. 2d 753; 602 N.Y.s. 2d 709; 1993 N.Y. App. Div. LEXIS 9845.
  • In the matter of J.F. v. L.F., Fam. Ct. of NY, Westchester Cty, 181 Misc 2d 722; 694 N.Y.S. 2d 592; 1999 N.Y. Misc. LEXIS 357.
  • Oliver V. v. Kelly V., NY Sup. Ct. Part 12. New York Law Journal Nov. 27, 2000.
  • Sidman v. Zager, Family Court, Tompkins County, NY: V-1467-8-9-94.


  • Sims v. Hornsby, 1992 WL 193682 (Ohio App. 12 Dist., Butler County, Aug 10 1992).
  • Zigmont v. Toto, 1992 WL 6034 (Ohio App. 8 Dist Cuyahoga County, Jan 16, 1992).
  • Pisani v. Pisani, Court of Appeals of Ohio, 8th App. Dist. Cuyahoga Cty. 1998 Ohio App. Lexis 4421 (1998).
  • Pathan v. Pathan, Case No. 96-OS-1. Common Pleas Court of Montgomery County, OH, Div. of Dom Rel.
    • Pathan v. Pathan, C.A. Case No. 17729. Ct. of App. of OH, 2d Dist., Montgomery County; 2000 Ohio App. Lexis 119. Jan. 21, 2000
  • Conner v. Renz, 1995 WL 23365 (Ohio App. 4 Dist., Athens County, Jan 19, 1995).
  • State v. Koelling, 1995 WL 125933 (Ohio App. 10 Dist., Franklin County, Mar 21, 1995).


  • Popovice v. Popovice, Court of Common Pleas, Northampton Cty, PA. Aug 11, 1999, No. 1996-C-2009.


  • Ochs et al. v. Myers, App. No. 04-89-00007-CV. Ct. of App. of TX, 4th Dist., San Antonio; 789 S.W. 2d 949; 1990 Tex App. Lexis 1652, May 16, 1990.


  • Ange, Court of Appeals of Virginia, 1998 Va. App. Lexis 59 (1998).
  • Waldrop v. Waldrop, in Chancery No. 138517. Fairfax County Circuit Court,(Va., April 26, 1999).


  • Rich v. Rich, Sup Ct, 5th Dist. Case No. 91-3-00074-4 (Douglas County) June 11, 1993.


  • Janelle S. v. J.R.S., Court of Appeals of Wisconsin, District 4. 1997 Wisc. App. LEXIS 1124 (1997).
  • Fischer v. Fischer, Ct. of App. of WI, Dist. Two, No. 97-2067; 221 Wis. 2d 221; 584 N.W.2d 233; 1998 Wisc. App. Lexis 1534.


  • In re Marriage of Rosenfeld, 524 N.W. 2d 212 (Iowa App., Aug 25 1994) McCoy v. State 886 P.2d 252 (Wyo.,Nov 30, 1994).
  • McCoy v State of Wyoming, 886 P.2d 252, 1994.

CANADA (8 Provinces)

Parental Alienation - Canadian Court Rulings

Updated August 6, 2008

All Canadian laws, including provincial, territorial and federal laws, and many court decisions can be viewed for free on the website of the Canadian Legal Information Institute at: Link opens in a NEW browser window www.CANLII.org

The reference to Carswell: Carswell is a legal information publisher.


  • Elliott v. Elliott, A.J. No. 74 DRS 96-05285 Action No. 4806-10272 Alberta Crt of Queen's Bench, Jud. Dist. of Lethbridge/Macleod, Jan 25, 1996.
    • Elliott v. Elliott, 1996 Carswell Alta 95, 193 A.R. 177, 135 W.A.C. 177, 27 R.F.L. (4th) 23 Alberta Court of Appeals. Nov 7, 1996 (Affirmed--Appeal Dismissed)
  • Johnson v. Johnson, No. 4806-11508a, Jud Dist. of Lethbridge/Macleod, Oct. 09, 1997

British Columbia

New Brunswick

  • S.O. v. S.C.O, N.B.J. No. 326, Proceeding No. FDSJ-400-98. New Brunswick Crt of Queen's Bench, Family Division-Jud. Dist. of St. John. Jul 28, 1999.
  • Jefferson v. Jefferson, New Brunswick Court of Queen's Bench Docket: FDSJ-6408.95. 2000 CarswellNB 15. Jan 18, 2000.

Newfoundland and Labrador

  • Toope v. Toope, 2000 Carswell Nfld 185, 8 R.F.L. (5th) 446, 193 Nfld. & P.E.I.R. 313, 582 A.P.R. 313. Newfoundland Unified Family Court June 15, 2000.

Nova Scotia

  • Badakhshan v. Moradi, Nova Scotia Fam Court. 1993 CarswellNS 423;120 N.S.R.(2d) 405; 332 A.P.R. 405. Mar 2, 1993.

Ontario (Updated with the Turnbull and McWatt decisions March 2/09 as well as the search link on CanLii.org)

  • Rothwell v. Kisko, 1991 CarswellOnt 1326. Ontario Crt of Just. (Gen'l Div.) Docket# 36429/89, Mar 21, 1991.
  • Davy v. Davy, Ontario Court of Justice (Gen'l Div)Docket 92-gd-21948. 1993 Carswell Ont 1630;1993 W.D.F.L 1535. Oct 7, 1993.
  • Fortin v. Major, O.J. No. 3805 DRS 97-01672, Court File No. 49729/94 Ontario Crt of Justice (Gen'l Div: Ottawa), Oct 25, 1996.
  • Demers v. Demers, Ontario Superior Court, Docket: Kingston 54253/96. 1999 Carswell Ont 2621. June 8, 1999.
  • Orsak v Orsak, Ontario Superior Court of Justice Docket: 97-FP-234664. 2000 Carswell Ont 1574. May 5, 2000. http://www.canlii.org/en/on/onsc/doc/2000/2000canlii22529/2000canlii22529.html PDF Click here
  • Her Majesty the Queen vs. K.C. Superior Court of Justice, Ontario, County of Durham, Central-East Region, Court File No. 9520/01. August, 9, 2002. (Mohan Test)
  • Rogerson v. Tessaro, Court of Appeal for Ontario, Docket: C44199, May 9, 2006. [mentions alienating conduct but not "syndrome."] http://www.canlii.org/en/on/onca/doc/2006/2006canlii15126/2006canlii15126.html PDF Click here
  • Petternuzzo-Deschene v. Deschene, Ontario Superior Court of Justice, Docket: 22661. 2007 WL 22984642007 (Ont. S.C.J.), Carswell Ont 5095. August 8, 2007. [specifically mentions PAS and cites a description of alienating behavior as abuse]
  • S.P. and P.B.D., Ontario Superior Court of Justice, Court File No. 22661. August 10, 2007. http://www.canlii.org/en/on/onsc/doc/2007/2007canlii31787/2007canlii31787.html PDF Click here
  • J.K.L. v. N.C.S., 2008 CanLII 30289 (ON S.C.) — 2008-04-22, Ontario — Superior Court of Justice, child — severe PAS — parent — father — time cited by 3 cases , Turnbull decision transferring custody to Mother, 13 year old son sent to therapy, Dr. Richard Warshak Expert Witness. PDF Click here
  • A.G.L. v. K.B.D., Ontario Superior Court of Justice, Court File No.: 99-FP-246860FIS, Date: 20090116, J. Mcwatt decision changing custody of 3 daughters to father after 10 years of PA. Severe PAS, Dr. Richard Warshak Expert Witness. Mother to be restrained from seeing children for a time. PDF Click here
  • S.G.B. v. S.J.L., 2009 CanLII 4523 (ON S.C.) — 2009-02-06, Ontario — Superior Court of Justice , arbitrator — father — children's best interests — parental alienation — apprehension of bias. PDF Click here


  • Stuart-Mills, P. v. Cher, A.J.., Sup. Ct. Quebec, Dist. of Montreal, No. 500-12-184613-895 (1991).
  • V. (L.) C. H. (E.), 1992 CarswellQue 169; 45 Q.A.C. 100; 1992 R.J.Q. 855; 1992 R.D.F. 316 Cour d'appel du Quebec, Feb 26, 1992.
  • R.M c. B.R, [1994] A.Q. no 947. DRS 95-09809 No 200-09-000440-948 (200-12-042928-904 C.S.Q.) (Quebec, decision in French only) Oct. 28, 1994
  • R.F. v. S.P., [2000] Q.J. Np. 3412 No. 500-12-250739-004 Quebec Superior Court (Montreal) Oct. 13, 2000.


To get up-to-date information on your province go to http://www.canlii.org/en/index.php, click on your geographic preference to the left, type Parental Alienation into full text, type in decision date on left, 2008 (or year you want) and then type 2009 on the right or leave blank. Click on search.


  • Johnson v. Johnson, 4806-11508A. FAMILY COURT OF AUSTRALIA, July 7, 1997.
    • Johnson v.Johnson, Appeal No. SA1 of 1997 No.AD6182 of 1993, 7 July 1997.


  • Familycase Koudelka/Application number: 1633/05, 20 July 2006
  • Familycase Zavrel/Application number: 14044/05, 18 April 2007


  • Anonymous v. Anonymous, Case No. 2xv178, Rinteln (Circuit Court) Germany, Apr. 27, 1998.
  • Sch. v. Sch., Kammergericht KG Berlin. vom 30 Mai 2000 - 17 UF 1413/99.
  • Fundstelle: Fam RZ 2000, 1606 (Heft 24 / 2000 vom 15. Dezember 2000) "¤¤ 1671, 1696 BGB: Bedeutung des Parental Alienation Syndroms im AbŠnderungsverfahren" - Hervorhebungen durch Fettschrift - Beschluss 17 UF 1413/99 - Volltext der Entscheidung (136 F11 514/98 AG Berlin (Tempelhof-Kreuzberg Germany)
  • Anon v. Anon, OLG Ffm vom 13.07.2000 unter Az. 5 WF 112/00,(Germany).
  • Anon v. Anon, OLG Ffm vom 26.10.2000 unter Az. 6 WF 168/00,(Germany).
  • Anon v. Anon, OLG Dresden, No. 264 - UF229/02, Aug. 29, 2002 (published in FamRZ: 50(6) 2003: 397).


  • Re: C (Children) (2002) CA (Dame Elizabeth Butler-Sloss P, Thorpe LJ, Kay LJ) 20/2/2002 COURT OF APPEAL REF: 2001/1642. (Great Britain)



  • Entscheid der delegierten des AmtsgerichtsprŠsidenten II con Luzern-Stadt vom 8. Februar 2001 im Verfahren nach Art. 175 ZGB (02 00 210)




Sunday, June 15, 2008

David Warren ~ The Ottawa Citizen on Father's Day

I didn't see both of my youngest children on Father's Day but I did see both on the Saturday preceding Father's Day. That was a gift and we went out to dinner accompanied by two of their friends. I count it has a Father's Day weekend visit and relatively speaking that is a good thing. I did have my 9 year old for the weekend and my adult daughters contacted me on Sunday. I was a lucky Dad. This blog has helped me get to this point. My book will expose the seamy underbelly of abuse tolerated by the courts and other feminist enablers in child protection/social services including the Ontario Works cheerleaders who have left me with the appearance of ignoring welfare fraud on behalf of some of their female clients et al.

The seeing of both my children on this weekend, albeit not Father's Day, is a far cry from the ex's previous behaviour in deliberately denying my the ability to see them through supervised access in 2006 by canceling the visit. I'll not ever forget those cruel and deliberate acts of pure revenge she has perpetrated on my children.

David Warren The Ottawa Citizen

Sunday, June 15, 2008


For some tens of thousands of fathers, in this Canadian province alone, "Father's Day" is an especially bitter occasion. These are the men separated from their children by court order, many never to see them again. Each knows that his children have been subjected to vicious propaganda against him, that in many cases a child's own mother -- a woman the father once trusted enough to marry -- has turned the child's heart against him. (I know of many cases.)

It could be worse: for the father may have been replaced in his own household by a new man, or even a new woman. Someone who will never care for his children as he did, however badly he may have expressed it; who will at least be lacking the biological compulsion to look out for one's own flesh and blood.

In a further twist, whether or not mom has found a new squeeze, the ostracized dad may be making court-ordered spousal support payments sufficiently onerous to put him on a cot in some closet -- hounded by process servers, and under the threat of jail if his payments fall behind. (I know this experience at first hand.)

There is no cure for it. The legal papers make clear -- go to lengths to make clear -- that he will be hounded until the day he dies. Male suicide rates, not only in this province but across North America, are at their highest level since the depth of the Depression in the 1930s. They are four times higher than the female suicide rate, and while no government has the guts to gather statistics on this, it is an easy guess that family court disasters lie behind a large proportion of them.

The legacy of feminism has been to make us acutely aware of women's sensibilities, no matter how frivolous; and obtusely indifferent to men's, no matter how grave. Men are consistently demonized in the feminist propaganda, women consistently presented as victims, in defiance of the facts of human nature, which show the capacity for evil to be well-distributed. Under the pressure of feminist lobbying, our entire family law system has been skewed so that the man almost invariably pays, the woman almost invariably collects, regardless of the circumstances. Only in the most extraordinary cases is the man granted custody of the children, or even equal access.

The keystone of the feminist order is "domestic violence." Men are so universally presented as having "anger management issues," that even in the extreme case, where a woman has murdered her husband, the court will invite feminist "experts" to argue that the man must have deserved it. And the man in this scene is unable to defend his own posthumous reputation, for dead men tell no tales.

The statistics show domestic violence to be well-distributed between the sexes, although there are knots and wrinkles before we get to that result. For instance, men are actually more likely to physically bully and abuse women than vice versa (on the average, women are physically smaller). On the other hand, women are more likely to physically bully and abuse children and the elderly (who are smaller and weaker than they).

And there can be no justice, no approximation to justice, unless each charge is considered on its merits, free of malicious, "politically correct" ideology.

I hold no brief for men, or women. They are absolutely necessary to each other, and on their mutual sympathy the future of every society depends. Very few men or women are saints. By no means is any father, who has fallen afoul of, say, Ontario's Kafkaesque "Family Responsibility Office" entirely innocent. At the very least he exercised poor judgment in his selection of a mate.

But men are not exceptionally evil, nor women neither. Some of each are monsters, in their several ways.

All are subject to temptations, and our skewed family law has the effect of putting so many temptations in the way of women, that many fail to resist. Not because they are women, but because of skewed law, many women employ the dirty tactic of laying false charges that, under our present order, will immediately get them custody and whatever else they may

want -- with little risk of punishment, even if they are caught lying. This simply stands to reason.

Indeed, the removal of common sense from family law -- and its replacement, over the last two generations, with various feminist mantras -- has made this problem almost impossible to fix. For the debate is now inevitably over, "How much feminism is the right amount?"

Whereas, there is no "right amount" of feminism, if feminism has become a hateful ideology declaring that the interests of one class (women) take priority over the interests of another (men).

To those fathers who had the wisdom to marry good women, and who wake this morning to the joy reflected in the face of each beloved child: You have your reward, and it is very beautiful. Join us now in praying for all the others.

David Warren's column appears Sunday, Wednesday and Saturday.

© The Ottawa Citizen 2008



Parental Alienation has reached the Canadian mainstream media. MACLEAN'S Magazine in Canada is a weekly publication targeted at Canadian adults who want information in a colourful glossy magazine format. It gets no more mainstream in this country and is similar in timing to the U.S. publication called Time Magazine. I haven't yet researched the newspaper which is quoted in the interview and editorialized "judicial reaching on a gargantuan scale," and says "it has the potential to cause further harm." Whoever wrote that has their head up their ass – pardon my street language - but what does it take to wake society up to this abuse. I will try to find out which paper wrote it and then write my own editorial. I came across a web site that had the start of the quote and it is attributed to the the Globe and Mail. I have already sent my comments to them and left this remark on the website hosting a portion of the editorial in the G&M which started like this but payment is required to see the rest:

Trying to force filial love Sending a 13-year-old to a forced "deprogamming" to teach him to love his mother, as an Ontario judge has just done, is a bizarre way to try to overcome the ...


My comments on this site are as follows:

The writer of this article obviously has NO experience at the insidious and abusive nature of Parental Alienation and its impact, not only on the child (children) but the target parent or the extended family. It is naive in the extreme to think the program will teach love. It will not but it will help the child to understand better what has happened and give him the tools required to re-engage with the other parent. I find it hard to believe the writer had their head so far up their gluteus maximus. No one can possibly know the absolute devastation this form of child abuse has until they become a target. Ask Alex Baldwin or write me at parentalalienationcanada@(no spam)gmail.com. Remove no spam and brackets.

KEN MACQUEEN | June 4, 2008 |

Can the courts tell someone who to love? They must try, decided Ontario Superior Court Judge James Turnbull, in a recent ruling involving the case of "L.S.," a 13-year-old boy systematically brainwashed by his father to hate his mother. "Parental alienation is a difficult issue increasingly faced by the courts," said Turnbull. In a bold move, he granted the mother sole custody of her estranged son. The ruling gives her the right to transport him — against his will, if necessary — for treatment to counteract years of "subtle emotional abuse" by her ex-husband. Turnbull based much of his ruling on the testimony of Dallas-based clinical psychologist Richard Warshak. L.S. and his mother will participate in a four-day program Warshak helped devise to counteract such alienation. Warshak is the author of Divorce Poison: Protecting the Parent-Child Bond From a Vindictive Ex.

Q: Explain parental alienation.

A: What I call divorce poison are the things parents do that undermine the relationship with the other parent. It can range from occasional badmouthing to a vicious campaign to remove the parent from the child's life. When children succumb to this kind of negative influence they begin to treat the other parent with contempt, or with fear. The term that I've come to use is pathological alienation because I want to distinguish this problem from situations where a child has good reason to reject a parent.

Q: Is pathological alienation an act of love, or of hatred toward the children?

Continued Below

Click here to find out more!

A: I do think this is the most under-recognized form of emotional abuse toward children. What happens is parents who do this are so caught up in their emotions that they lose sight of their children's needs. They don't deliberately intend to hurt their children. The children are just collateral damage.

Q: Can you give examples from your experience of how this brainwashing is done?

A: It usually begins with a theme: "Your mom left us." Or, "Your dad goes on business trips because he doesn't care about us." The parent's love for the child is put in question: "She never really wanted you." Sometimes a parent's past mistakes are exaggerated. Other times entire episodes are manufactured to make the parent look bad to the child.

Q: That's particularly evil.

A: In some cases, children's memories of the good things that were done are wiped out, so they don't remember that the parent was present at an important event. Even though the parent has pictures to prove it, the child's negative view is so fixed that they discount the evidence. Attempts by the rejected parent to reach the child, such as gifts and cards, are withheld. In one case a girl was told that if her father really wanted to see her he would have sent money for airfare. A few years later the girl found a drawer full of plane tickets that the father had purchased and sent and the mother had hidden. In another case a woman who was in her 30s reconciled with her father after her mother died. She told him she could never get over the fact that he didn't provide money for her to attend college. So he pulled out his cancelled cheques that amounted to four years of tuition that he had sent to the mother but the girl had never seen.

Q: You say in your book that rejected parents sometimes contribute to their victimization by maintaining a stoic silence or just by refusing to indulge in a similar sort of slander about their ex-spouse. It's not always a good idea to remain passive?

A: It's not a good idea to remain passive. Certainly it's not a good idea to react by doing your own badmouthing. The single biggest mistake that parents and the professionals who advise them make is to do nothing. This leaves children with no help or understanding of what is at best a confusing situation. In any other situation when children misperceive reality we help correct their distortions. If children act hatefully toward people of another race or religion we teach the importance of judging people fairly and treating them with dignity. This is no less essential when the targets of animosity are parents and other relatives.

Q: What is the price children pay for writing off one of their parents?

A: The most serious consequence is the loss of the parent and sometimes the loss of half their family. It's not uncommon for these children to reject not only the parent but anyone associated with that parent. It's common knowledge when you have problems with your parents it handicaps your future relationships. In addition to that, though, there is long-term damage to the child's personality and character. As adults they suffer low self-esteem. Some children feel very guilty for having mistreated the other parent. These are the children who've come to understand what has happened to them.

Q: It's a matter of public record that you recently testified in an Ontario Superior Court case in which a 13-year-old boy was judged to have been systematically brainwashed by his father. What prompted your intervention?

A: I'm sorry but I can't speak about any case in which I've been involved, even if it is a matter of public record.

Q: Can you tell me if it is unusual for you to testify in court in these situations?

A: Most of my time is spent doing my research, writing and helping families in my office. I get many, many requests to testify in cases. Most of these I turn down. When I do offer testimony, I do my best to educate the court about the nature of the problem and the options available to remedy it.

Q: In this case, Judge Turnbull seemed impressed by your proposed remedy. His ruling caused a bit of a stir in Ontario. He ordered this boy be flown, against his will if necessary, to this program you helped design, the Family Workshop for Alienated Children. Would that be an unusual ruling?

A It's becoming more common as the courts learn about the damage to children in the present and on. Particularly when judges learn they hold the power to help the family, judges are more willing to tell kids that they don't get to choose their parents just as they don't get to vote or drink alcohol. Not only do the kids have to stop acting like entitled adults, the judges tell the grown-ups to stop acting like kids.

Q: A newspaper report of that case calls the program "a facility that deprograms children." Is that how you would describe it?

Continued Below

Click here to find out more!

A: Not at all. This is a gross misconception of the work we do. Our program teaches children how to stay out of the middle of adult conflicts, and how to maintain a compassionate view toward each parent. We teach children to think critically. When children learn how to see a problem from different perspectives they usually begin to heal their relationship without having to acknowledge that they had been treating the parent with contempt and without having to apologize for it. They begin relating in a more positive way.

Q: Yet I understand that, to varying degrees, children can be forced to attend, either through a court order or by being physically escorted to the workshop. This is after the courts have already said they're going to make them live with a parent they've already rejected. It sounds like a recipe for disaster.

A: Again, what we have going for us is that the child really has an underlying wish to get out of this bind. I should clarify that often it is not the judge who orders the child to attend the workshop. Rather, the judge awards decision-making authority to the rejected parent who may then choose to enrol the child in the program, just as the parent is free to make other decisions regarding the child's health and education. Our program is designed to jump-start the reconciliation and offer a safe way to contain a child's anxiety and conflict. It's a misconception that the children are restrained. No child has been brought to me in restraints, and I would never work with a child under such conditions. They are oftentimes lectured by the judge about the necessity that they repair the damaged relationship. Once they understand they no longer hold a power that they should have never been given in the first place it's remarkable how much they co-operate.

Q: A newspaper editorial on the Ontario case calls this "judicial reaching on a gargantuan scale," and says "it has the potential to cause further harm." How do you respond?

A: Again, I won't discuss any specific case but the courts sometimes have to make difficult decisions. In another context, a court would not allow a child to live with the consequences of a major life decision made at such a young age, and under emotional distress. For instance, physically abused children will commonly plead with authorities to allow them to remain in the abusive home. But despite their protests, we protect children from abuse in the interest of safeguarding their long-term needs. If children refuse to attend school or seek necessary medical treatment, it is considered perfectly appropriate to require them to comply.

Q: How long does a workshop last?

A: The initial phase lasts four days in terms of our work with the child and the rejected parent. This seems kind of rapid.

Q: I'll say.

A: Traditional attempts to help this problem usually involve weekly therapy sessions. And after two years the therapist decides the treatment has been a failure, at which point the child is even older and it's more difficult to reverse the problem. When divorce poison takes hold it often works so rapidly that a child who is loving one day acts hateful the next. Fortunately, reversing the problem can almost be as rapid. What we have on our side is that the child wants to reconnect with the parent and wants to be released from the bind in which he's found himself. Certainlyin four days we can't undo all the damage of years of living in a family war zone.

Q: That was my next question.

[object Object]

Q: You've got some major parental repair work to do as well then?

A: We do. And in truth we're not as successful with [alienating] parents as we'd like to be. We have much more success in healing the damaged relationship the child has with the parent who was rejected. We have had success with the other parent sometimes but in other cases they have no interest in co-operating. In the most unfortunate situations, the other parent will end up rejecting the child themselves. "If you're not on my side you're against me." Even if the other parent does not change their attitude the children can learn enough often to withstand that kind of influence without succumbing to it.

Q: They're inoculated?

A: Yes. We give the children the tools to be children and to stay out of adult conflicts.