Tinto & Dawhurst 2014 FamCAFC 16

A child aged 6 years had lived with the mother for 5 years.  A psychiatrist gave evidence that the mother met 7 of 9 criteria for  borderline personality disorder, and recommended psychological therapy (personality emotionally volatile).  The judge ordered that the child live with the father, that the father have sole parental authority, and that the mother have supervised access.  The judge ordered that the mother participate in therapy as a condition of having access to the child (access conditional, therapy for parent).

A family consultant described the relationship between the parents as being destructive and co-dependent, with angry scenes during the relationship of 13 years (high conflict couple).   The mother when untreated had displayed episodes of rage where her behaviour was unrestrained, showing poor regulation of her emotions in front of the child (parenting style emotional).  The judge considered that the mother did not understand the child’s emotional needs (child focused).

The mother appealed the orders.

The appeal was dismissed.