What is the test for a change in a child’s behaviour in a residential unit?
Ontario, Canada
The following excerpt is from Easson v Blase, 2015 ONSC 5170 (CanLII):
Change is not enough. The change must have altered the child’s needs or ability of the parents to meet the child’s needs in a fundamental way [Gordon v. Goertz, supra, para 12].
Further, the change should represent a distinct departure from what the courts could have reasonably anticipated in making the previous order [Gordon v. Goertz, supra, para 12].
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