Coercive Control Takes Center Stage in Alberta Relocation Case

In a significant Alberta decision earlier this year, Laurence v Ross, 2025 ABKB 131, Justice Loparco offered a detailed and thoughtful analysis of coercive control and family violence, in the context of a mother’s request to relocate with her five-year-old child from Calgary to Quebec.

This wasn’t just another relocation case.

While the court considered best interests and mobility factors, what truly set this decision apart was its attention to the subtle, sustained patterns of emotional abuse and coercion.

Key factors that supported Justice Loparco's decision:

1. Mother’s stable work schedule in Quebec

2. Mother’s continuous history of care

3. Availability of family support in Quebec

4. Mother’s financial and emotional well-being as the primary caregiver

But most impactful was the court’s recognition of coercive control as family violence.

Justice Loparco agreed to the following principles regarding family violence:

• Family violence is often insidious, carried out by skilled manipulators behind closed doors, which can make it difficult to detect or prove.

• Belittling or denigrating a partner in front of the children can constitute family violence.

• Abuse doesn’t need to be physical—emotional and psychological harm can be equally damaging, especially to children.

• Intentionally withholding or minimizing financial support can be a form of family violence.

• Delayed disclosure and inconsistent accounts are common among victims of abuse and should not be taken as evidence that the abuse didn’t occur.

• Coercive control is often subtle and cumulative, sometimes only fully recognized by the person experiencing it.

Albeit the parties were not married, Justice Loparco stated:“The more expanded definition of family violence in the Divorce Act can be adopted for matters that fall within the Family Law Act.”

It is important to note that this broader lens allows the court to recognize abuse beyond the physical when accounting for the child’s best interests.

Justice Loparco found that the father’s consistent, patterned, insidious behavior over time constituted coercive control and family violence. Behaviors include:

• Repeatedly using abusive, condescending, and insulting language to disparage the mother

• Threatening that the mother “will pay”

• Frequently expressing hatred towards the mother

• Taking out loans in the mother’s name without her consent and refusing to make payments on those loans

Ultimately, the court ruled in favor of the mother, finding that relocation would support the child’s well-being and protect them from ongoing exposure to coercively controlling behavior.

For anyone working in family law:

Laurence v Ross is essential reading. It’s another step toward a more realistic, trauma-informed legal system—one that sees beyond the surface and puts children’s safety and stability first.

And for those living through it:

If your experience includes patterns of control, manipulation, or emotional abuse—even in the absence of physical violence—know that the legal system is increasingly acknowledging these dynamics.

You’re not imagining it, and you don’t have to go through it alone. There are supports and legal tools available to help protect both you and your children.