The respondent father brought a motion to change a final order that had terminated his access to his two children due to a history of emotional abuse, harassment, and anger issues directed at the applicant mother and witnessed by the children.
The court applied the two-stage test from Gordon v. Goertz, finding that the father failed to demonstrate a material change in circumstances.
Despite engaging in minimal psychiatric consultation and an anger management course, the father lacked insight into his past abusive behavior, continued to blame others, and did not adequately address his mental health issues.
The court dismissed the motion to reinstate access but ordered the parties to use an online communication platform for child-focused information exchange and restricted the father from bringing further variation applications for 15 months without leave.