The Order of Battle
An Angry Mother's 'Checklist'



Warning! One important thing about this section needs to be understood up front.

'The Checklist' is a necessary evil, and must be read only in the context of a high-conflict custody dispute. Please bear in mind while reading this that it describes the known behaviour of a very small percentage of women indeed. It refers only to those weak, insecure women whom the family courts have taught to behave in this way by letting them get away with it. It does not purport to describe women in general.

We publish 'The Checklist' because if your children's mother had not already proven herself part of that small, vicious minority, you wouldn't be here reading these words.
We know that the very great majority of women would never stoop to such behaviour and that they are horrified at seeing other women do so...just as men are disgusted by those few mindless males who abuse those weaker than themselves.

In a high-conflict custody war, the accusations your children's mother will make against you are predictable. So are the tactics and manœuvres she will use in order to deny you custody. These tactics are so uniform that many men believe there is a 'TO DO' list handed out secretly to mothers by women's organisations. While a printed list may not actually exist, the result for fathers is the same as if it did. The items on that virtual 'list' are well known by now. Some women do not have the courage to deal honestly with the fact their relationship has failed. They are easy prey to the temptation to use these tactics, especially when they are suggested by an attorney, a women's social worker, a sister, or a girlfriend.

So herewith 'The Angry Mother's Checklist'. If you know what to expect in advance, you will be less likely to be taken by surprise. This will put you in a better position to counter the accusations or head them off in the first place. These are the most common tricks, along with recommendations on what defensive or preventive measures you can take.
  1. She may try to accuse you of some form of violence against her, or the children, or both. 
  • The best defense against this sort of accusation is to demand detailed dates, times, and specifics, as well as corroborating physical evidence. If the accusation is false,  she will have to fabricate a complicated and cohesive series of lies, and most people are not able to do that without 'biting their own tail' somewhere in the story.
  1. If she has no evidence of any form of physical violence, she may try to accuse you of theatening her or of threatening the child. 
    • Even this is sufficient in many jurisdictions (especially the U.S.) for her to obtain an ex parte* restraining or protection order. The same advice applies to this as to accusations of actual violence. Demand details. If she's lying, encourage her to keep on lying until she makes a mistake and contradicts herself.
  1. She may try to accuse you of sexual abuse. 
  • This is known as the 'nuclear bomb' of custody disputes.  It is a topic so sensitive and emotionally charged that just making the accusation is usually enough for her to get a court order keeping you away from the children. The best defense against this is the same as above: demand details and physical evidence. [Click here for more information about false sexual abuse accusations.]
  1. She may try to accuse you of psychologically 'controlling' her in a systematic way by 'putting her down' and/or refusing to listen to her 'wants and needs.'
  •  She may try to back this claim by submitting the 'diagnosis' of a psychologist she's consulted privately or at a women's center. The best defense against this is to object to the diagnosis being presented as evidence because the consultation she had with the psychologist was not a court-ordered psycho-legal assessment. This is a valid defense in some jurisdictions. 
  1.  She may try to have you portrayed as megalomanic, obsessed, and paranoid.

    • In most jurisdictions, she cannot submit any expert testimony as to this without you both having undergone a psycho-legal assessment ordered by the court. If she simply makes the claim during her testimony, object on the basis that she is not professionally qualified to make such a diagnosis.
    • A great danger in this type of accusation is what psychologists call 'Projective Identification Syndrome', in which the victim becomes what he is accused of being solely as a result of the accusation itself. [Click here for more information about Projective Identification and how to avoid it.]

  2. If you  have a police record, no matter how minor, she will almost certainly try to use that against you.

    • Make sure your attorney knows of any record you may have so that he can be prepared to deal with this. You can be sure your wife's attorney will have a complete records search done on you even if your wife hasn't told her about any incidents she personally knows about. Allowing your attorney to be surprised in open court with something like this is a sure way to lose, even if the charges against you had absolutely nothing to do with your wife, your children, or women or children in general.

  3. If you have ever gone for psychiatric or psychological counseling, she may try to use that to claim you are mentally unstable, or a danger to yourself or to the child.

    • You will need to get in contact with the professional you consulted and obtain his diagnosis to counter this claim. Get that in writing, notarised, before she makes the claim and keep it in reserve in case you need it. In many jurisdictions, this may be acceptable as evidence in defense against her claim, because she raised the issue first. 

  4. If you use 'recreational drugs' of any sort, she may try to force you to have a drug test and then use the results to claim you are an unfit parent. The same goes if you abuse or have ever abused alcohol. 
  1. She may deliberately try to get you angry enough to hit her, so that she can have you arrested for assault. 
  • YOU MUST NOT LET HER GET YOU ANGRY ENOUGH TO LOSE CONTROL. The instant you touch her--no matter what she's done to you to 'deserve' it--you are finished. Even if she hits you first, keep your hands in your pockets and run for it. Call the police and have her charged. DO NOT TOUCH HER UNLESS YOU ARE IN REAL AND IMMEDIATE FEAR FOR YOUR LIFE (OR YOUR CHILD'S LIFE) AND WILL BE ABLE TO PROVE IT AFTERWARDS. Keep that in mind every single time you see her. [Click here for a list of techniques to help you keep your temper.]
  1. She will try to change everything about the child's environment as much as possible to turn the children against you.
  • This is called 'Parental Alienation', but it is a particularly insidious form of it. Instead of telling the children bad things about their father, she tries to break the bonds they have to their existence with him by eliminating or changing physical aspects of their lives.
  • We must warn you that if you try to stop her, or tell the children what she's doing is bad for them, you will be accused--probably successfully--of parental alienation even though it is she who is actually doing the alienating. Again, we know this is not fair, but that is the way it is right now. 
  • You will have to deal with it by being patient, and letting the children know it's okay and that you love them even if she shaves them bald (this has been known to happen).  Keep up your own standards when the children are with you (if you get to see them at all), but do not be aggressive about it. [Click here for more information about Parental Alienation Syndrome.]
Next: The Fathers Field Guide to Survival

The Rules of Engagement
The Order of Battle
The Father's Field Guide


*An ex parte order is one which is issued on the demand of one party only. The hearing is held without the other party to the dispute being notified of it or present in the court. Because the adverse party has no opportunity to present arguments against the granting of the relief sought--usually an order not to do something--to obtain such an order, the petitioning party normally has to prove that irreparable and imminent probable harm will befall her if the adverse party learns of the application before the order is granted. In any other sector of judicial proceedings except family court, the burden of proof is generally very heavy, as well it should be. However, in recent years, accusations of domestic violence have become virtually a tactical requirement for women in divorce proceedings, and in jurisdictions such as the U.S. family courts, ex parte restraining or 'keep-away' orders are granted to women almost on a rubber-stamp basis. Ex parte orders are temporary, and are granted until a full hearing with all parties present can be scheduled. At that time, the issue is re-examined and both sides are heard. [Return to text]

The material in the Fathers in Crisis pages was created by the World Fathers Union Crisis Group. The Group is composed of members working from both personal experience and professional knowledge. Lead authors were John F. Smith (CAN) and John T. Smith (CAN/UK). Special thanks go to our contributors and consulting members, including attorneys John A. Smith (USA) and John K. Smith (USA); child and family psychologist John P. Smith (NZ); Professor Jane J. Smith (USA); John P1 Smith (CAN); and Dr Mark Heitner, M.D. (USA). Many other members have also contributed to these pages by asking us hard questions about their own situations and making us search for good answers. The Union thanks them all.





WORLD FATHERS UNION: Working for fathers and children everywhere.World Fathers Union is an all-volunteer research and outreach NGO. We work to foster cooperation and unity amongst fathers-aid groups worldwide working for equity in the family courts of all nations. We do statistical research, compilation, and analysis of trends in social and legislative policy affecting fathers and children, and we provide outreach programs to fathers and children in distress worldwide. Membership in the Union is free, anonymous, and open to everyone.

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