Coercive Control and Parenting in Family Law in Alberta

In a recent decision at the Court of King’s Bench of Alberta, Laurence v Ross, 2025 ABKB 131, Justice Loparco provided clarity around how the Courts may address coercive control as a factor in the best interests of the children analysis in a parenting decision.

When the court hears a parenting application, they consider only the best interests of the child when determining what parenting should be. Specifically, they refer to the factors set out in section 18 of the Divorce Act, which is the legislation that addresses divorce in Canada.

In section 18(2)(vi) the Court is compelled to consider any family violence alleged in the family. In section 2 of the Divorce Act the definition of “family violence” includes behaviour which is defined as: “constituted a pattern of coercive and controlling behaviour that causes that family member to fear for their own safety or for that of another person.”

Justice Loparco considered case law from Ontario and made four general findings regarding family violence parenting cases:

1. Family violence can be insidious and inconspicuous, which makes it difficult to prove;

2. Denigrating a spouse in front of the children fits within the definition of family violence;

3. Violence need not be physical; emotional and psychological abuse can have devastating impacts on children; and

4. Controlling a spouse by deliberately making inadequate support payments can constitute family violence.

Justice Loparco cited with approval a case from Ontario called MAB v MGC, 2022 ONSC 7207, which confirmed that coercive control may consist of many different acts occurring over time which, in isolation, do not seem abusive or significant, but when viewed in their totality paint a picture of a very abusive relationship.

Coercive behaviour vs controlling behaviour

Coercive behaviour, in this context, includes conduct that is threatening, intimidating, or exerts inappropriate pressure on the other person.

Controlling behaviour is behaviour which is intending, or has the effect of, inappropriately managing, directing, or restricting a party’s life in some way.

Some examples of coercive control may be:

1. Engaging in verbal abuse, yelling, name calling and insults.
2. Making numerous unsubstantiated allegations against the other party.
3. Unilaterally changing court-ordered parenting time terms without justification.
4. Engaging in behaviour that has the effect of undermining the other parent’s authority or influence and alienating the child from that parent.
5. Making numerous unsubstantiated allegations of abuse to the police or other professionals.

Using the above indicators of coercive control, Justice Loparco found that there was family violence in Laurence v Ross. This finding was not based on one or more conspicuous acts, rather coercive controlling behaviour was found through a pattern of conduct that cumulatively caused psychological and/or financial harm to the mother.

Here are specific examples that Justice Loparco found contributed to the finding of family violence:

• Putting the mother down repeatedly;
• Blaming the mother repeatedly;
• Using abusive, condescending, and insulting language throughout an affidavit;
• Evading being contacted when knowingly withholding the child;
• Using offensive security questions on the e-transfer security question when providing support payments;
• Failing to provide full disclosure when required;
• Taking out loans in the other parties’ name without telling them;
• Refusing to continue paying loan payments to gain an advantage in parenting; and
• Threatening the mother that she “will pay for her actions”; and
• Putting the child in the middle of the parenting dispute.

Justice Loparco allowed the child to relocate with the mother in large part because the father’s overall lack of respect for the mother undermined his parenting ability. The father’s treatment of the mother is inextricably linked to the best interests of the child.

Overall, this decision from Justice Loparco clarifies what the Court of King’s Bench would consider to be coercive control, and it starts to lay a framework for how it may be considered family violence in the context of determining the best interests of the children.