24 July 2014

Reports on Justice Forums Released

The BC Ministry of Justice has just released its summary report (PDF) of the proceedings at the third justice summit, held on 4 and 5 May 2014 in Vancouver. The report offers no tidy synopsis, but the topics discussed included the early resolution of legal disputes, resolving legal disputes out of court, improving court processes, and assessing the outcomes of a reformed justice system.

These summits are mandated by s. 9 of the Justice Reform and Transparency Act. Reports on all three summits to date can be found on the Ministry's website.

Not to be outdone, Alberta Justice and Solicitor General has published its report (PDF) of the proceedings at the Joint Action Forum on civil and family justice held in Edmonton on 20 November 2013. The purposes of the forum were to discuss the current state of the justice system and what an improved, "citizen-centred" justice might look like, and discuss how movement toward a reformed system may be initiated.

11 July 2014

New Report on Legal Aid In British Columbia: Authors Argue Underfunding Breaches Human Rights Obligations

Lawyers' Rights Watch Canada has just released a draft report for public comment, "The Right to Legal Aid: How BC's Legal Aid System Fails to Comply with International Law" (PDF)Legal aid in British Columbia is administered by the Legal Services Society. The Legal Services Society is funded primarily by the provincial government; fund are also provided by the BC Law Foundation.

The authors of the new report argue that reductions in funding leave "even the most basic legal aid needs of British Columbians" unmet, with a disproportionate impact on women and marginalized groups, which ultimately undermines the "entire justice system." The authors also note that the inadequate funding of legal aid has social impacts that extend far beyond the justice system to affect the "social fabric of British Columbians and their economy."

Comment on this important report is open until 8 August 2014. Read the LRWC's statement on the new report. Read Ian Mulgrew's article on the new report from the Vancouver Sun.

06 July 2014

Judge Criticizes Limited Legal Aid Funding Available for Family Law Cases

On 3 July 2014, Mr. Justice Crawford, a distinguished judge of the British Columbia Supreme Court for the last fifteen years, released a partial decision in the case of M.J.A. v R.D.A. which, along with addressing custody and guardianship of the parties' two children, offers some commentary on the difficulties facing litigants who represent themselves in court and the sorry state of the legal aid coverage available in family law disputes.

If I understand the facts correctly, the mother started this case in 2010. The trial began with five days in November 2013 and continued over two days in March 2014. Although sufficient evidence was presented that most of the issues could be resolved, the judge determined that a needs of the child assessment under s. 211 of the Family Law Act was necessary and ordered that one be prepared. Both parties were of limited means, and although the father was able to engage counsel, the mother represented herself throughout.

After summarizing the circumstances leading to trial, the judge offered these comments about the mother's self-representation, the difficulty of self-representing and the effect it had on the efficiencies of the trial process, and the woeful state of legal aid coverage in family law matters:
"[11] What has happened is the mother has proven quite inadequate to deal with the circumstances of a court room. Nor have I had the privilege of a current sociological or psychological report to assist the Court in something as fundamental as ensuring the children maintain a healthy relationship with their mother. 
"[12] ... I would note that [Mrs. A] described the task of being her own counsel as 'challenging' and I agree with her, it is an art that only comes with years of labour in courtroom situations. The members of the public that have to go in to a trial process in a courtroom without counsel are severely challenged, and the need for adequate funding for legal aid was yet again played out in front of me. 
"[13] If Mrs. A. had counsel I venture to say the evidence in this matter would have been focused and the trial done in three days and if we had the benefit of a s. 211 report assessing the needs of the children and the abilities of the parents, I would have had a far better understanding of Mr. A.'s concerns and Mrs. A. concerns. However, in the absence of a sensibly funded family legal aid system, I am left to try and assist the parents and especially the children in moving on with their lives, keeping them stable in their father’s house (with his new partner) but seeking to gradually improve Mrs. A.'s access to the children to foster a relationship with her children, an aspiration which I note is shared by Mr. A."
I have often wondered about the difference in the cost of funding the services of a lawyer at legal aid's parsimonious rate versus the total cost to the system resulting from the inevitable delays, adjournments and false starts that occur when a litigant is forced to represent him- or herself. It is really more cost-effective to withhold legal representation from someone rather than cover the cost of counsel at $89 per hour?

(Interestingly, two studies recently completed by the Canadian Research Institute for Law and the Family discuss Alberta lawyers' and judges' views that self-represented litigants :
  • always or usually have unrealistic expectations about the outcomes of their cases;
  • usually or sometimes are less likely to settle than litigants with counsel;
  • generally achieve the same or worse outcomes on parenting issues than litigants with counsel;
  • generally achieve worse outcomes on support issues than litigants with counsel; and,
  • generally achieve worse outcomes on property issues than litigants with counsel.
Assuming that the observations of the bench and bar bear some relation to reality, they are yet another clarion call for the proper funding of legal aid in family law matters.)

One other aspect of this decision is worth noting, namely that the needs of the child assessment was ordered to be prepared by a family justice counsellor, a Ministry of Justice employee attached to the Provincial Court. Said the judge (cites omitted):
"[17] I have advised the parties I will seek a 'Views of the Child' report pursuant to s. 211 of the Family Law Act. In other words under s. 211, I will and do hereby order a report from a family justice counsellor to assess the needs of the children in relation to the family law dispute, the views of the children in relation to a family law dispute, and the ability and willingness of a party to a family law dispute to satisfy the needs of the children. I understand the New Westminster and Richmond Family Justice Centre will authorize the appropriate counsellor who I appoint to assess and report to the Court and to the parties no later than (and hopefully before) November 30, 2014."
This illustrates the rather important power of the Supreme Court to make use of Provincial Court family justice counsellors, whose assessments are prepared at no cost to the parties. Normally, needs of the child assessments used in the Supreme Court are prepared by jointly-retained psychologists, psychiatrists or registered clinical counsellors at a cost ranging anywhere between $5,000 to $15,000 — sometimes higher depending the assessor's need to travel and the complexity of the issues being looking into — and can usually be completed within three to six months. On the other hand, although the assessments of family justice counsellors are free, family justice counsellors are not psychologists, psychiatrists or registered clinical counsellors, only a limited number of them are trained to prepare these assessments and it can take a year or longer before their assessments are complete.

Assuming that the benefit of getting a needs of the assessments for free outweighs the waiting period and other disadvantages, the decision in M.J.A. v R.D.A. will be a useful precedent for lower-income parties.

02 July 2014

Child Abduction and AMBER Alerts

There seem to have been an unusually high number of AMBER Alerts lately and I thought I'd post a brief summary of the program and the parts of the Criminal Code that talk about child abduction.

AMBER Alerts

The AMBER Alert concept was developed in the United States in the late 1990s as a way of using their Emergency Alert System to broadcast information about child abductions as widely as possible as soon as possible. Although "AMBER" officially stands for "America's Missing: Broadcast Emergency Response," it's generally understood that the program was named for Amber Hagerman, a young girl who was abducted and killed in 1996.

In Canada, the AMBER Alert system is an agreement between the police forces, media and public agencies in each province that allows urgent public appeals for information to be distributed, usually by radio and television media interrupting their regular programming with special news bulletins. However, according to the RCMP's webpage on AMBER Alerts, such alerts are only intended for "the most serious, time-critical abduction cases" and are not "used for cases involving runaways or parental abduction, except in life-threatening situation."

According to the RCMP, AMBER Alerts can be activated when all of the following four criteria are met:
  • police have confirmed that an abduction has happened;
  • the victim is a child, or a person with a documented physical or mental disability;
  • police have reason to believe the victim is in danger of serious injury; and,
  • information is available that would assist in the recovery of the victim if broadcast to the public.
If you have information that could assist when an AMBER Alert is broadcast, call 9-1-1. For more information, see these AMBER Alert webpages for these provinces:
British Columbia
New Brunswick
Newfoundland and Labrador
Nova Scotia
Prince Edward Island
You can also sign up for free alerts delivered to your wireless device, provided by the Canadian Wireless Telecommunications Association.

The Criminal Code

The Criminal Code is the federal law that deals with criminal offences such as assault, possession of stolen property and abduction. There are four section of the Code that deal specifically with the abduction of children.
Under s. 280, it is an offence to unlawfully take a child under the age of 16 out of the care of a parent, a guardian or someone else with the lawful care of the child, against the will of that parent, guardian or person.
  • "Unlawfully" in this context means without a legal right. A police officer or a child protection worker might have the right to remove a child in certain circumstances. Someone with a court order allowing him or her to take the child would also have the right to remove the child.
  • A "guardian" is someone who has custody or control of the child, including as a result of a court order.
  • Someone who isn't a parent or guardian but has the "lawful care" of a child might be a child protection worker, foster parent or a corrections officer.
  • The abduction must be without the consent of the parent, guardian or someone else with the lawful care of the child.
  • Under s. 285, this section will not apply if taking the child was necessary to protect the child from harm. 
Under s. 281, it an offence for someone who isn't a parent, a guardian or someone else with the lawful care of a child to take a child under the age of 14 out of the care of that parent, guardian or person with the intention of depriving that parent, guardian or person of the child.
  • "Take the child out of the care" of a parent, a guardian or someone else with the lawful care of a child includes detaining the child, luring the child away, hiding the child or giving the child a place to stay.
  • The abductor must intend to deprive the parent, guardian or someone else with the lawful care of the child of possession of the child.
  • Under s. 284, this section will not apply if the person taking the child has the consent of the parent, guardian or someone else with the lawful care of the child. 
  • Under s. 285, this section will not apply if taking the child was necessary to protect the child from harm. 
Under s. 282, it is an offence for a a parent, a guardian or someone else with the lawful care of a child to take a child under the age of 14 contrary to the terms of a custody order, with the intention of depriving a parent, a guardian or someone else with the lawful care of the child of the child.
  • "Take a child" includes detaining the child, luring the child away, hiding the child or giving the child a place to stay.
  • The abductor must intend to deprive the parent, guardian or someone else with the lawful care of the child of possession of the child.
  • Under s. 284, this section will not apply if the person taking the child has the consent of the parent, guardian or someone else with the lawful care of the child. 
  • Under s. 285, this section will not apply if taking the child was necessary to protect the child from harm. 
Under s. 283, it is an offence for a a parent, a guardian or someone else with the lawful care of a child to take a child under the age of 14 with the intention of depriving a parent, a guardian or someone else with the lawful care of the child of the child, whether there is a custody order in place or not.
  • "Take a child" includes detaining the child, luring the child away, hiding the child or giving the child a place to stay.
  • The abductor must intend to deprive the parent, guardian or someone else with the lawful care of the child of possession of the child.
  • Under s. 284, this section will not apply if the person taking the child has the consent of the parent, guardian or someone else with the lawful care of the child. 
  • Under s. 285, this section will not apply if taking the child was necessary to protect the child from harm. 
  • The attorney general must approve charges under this section.
Under s. 286, having the consent of the child or saying that it was the child's idea is not a defence to a charge of abduction under ss. 280, 281, 282 and 283.

Other related offences include kidnapping (s. 279(1)), unlawful confinement (s. 279(2)) and hostage taking (s. 279.1).

Abductions by a Parent

One of the recent AMBER Alerts was broadcast on 28 June 2014 in response to a father's abduction of his nine-month old child. I am aware of concerns that have been raised to the effect that the AMBER Alert was inappropriate as the abductor was the child's father. However, the simple fact of parentage does not mean that a parent is entitled to the possession of his or her child or that a parent cannot unlawfully remove his or her child from the lawful care of someone else. 

Remember the criteria for the issuing of AMBER Alerts described at the beginning of this post. First, ss. 282 and 283 of the Criminal Code describe the circumstances when a parent's removal of his or her child can constitute abduction. Second, the fact that the abductor is a parent does not mean that the child is not in a life-threatening situation; in fact, a parent's willingness to breach a court order or take a child without the consent of the other parent suggests that the situation is somewhat volatile and that the risk to the child is elevated. (In the case of the recent alert, the Calgary Police Service's news release states that in addition to the charge of abduction, the father is also facing changes of uttering threats and breaching bail conditions. Allegations of violence and threats, whether true or not, are pretty much par for the course in cases of parental abduction.)

However, remember also that the RCMP's policy is to not issue AMBER Alerts when the alleged abductor is a parent. This is, in most cases, entirely appropriate. In high-conflict disputes especially, separated parents are often way too quick to push the panic button, whether out of genuine fear of harm, as a means of punishing a parent who is late returning the child or in an attempt to exact revenge or paint the other parent in a poor light. 

26 June 2014

SCC to Hear Appeal Involving Challenge to Validity of Child Support Guidelines

The Supreme Court of Canada today granted leave to appeal in the case of Strickland v Canada, a decision of the Federal Court. Two things make this unusual. First, the Supreme Court of Canada hardly ever grants leave to appeal in family law cases. Second, the appeal concerns the validity of the Child Support Guidelines.

The Child Support Guidelines were implemented by the federal government in 1997. They are a regulation to the Divorce Act; the Divorce Act is the federal law, in force across Canada, that deals with divorce, child support, spousal support and children's parenting arrangements after separation. (The Guidelines have been adopted by all of Canada's provinces and territories, except Quebec, as a part of their local laws on family breakdown.) The Divorce Act says that when a judge is making an order for child support, the judge must do so "in accordance with the applicable guidelines."

Although there are some exceptions, s. 3(1) of the Guidelines says that "the amount of a child support orders ... is ... the amount set out in the applicable table, according to the number of children ... and the income of the spouse against whom the order is sought." The tables are probably the Guidelines' best known feature and, as s. 3 suggests, they set out how much money must be paid as child support according to the payor's income and the number of children support is being paid for.

According to the decision appealed from, the appellants argued that the Child Support Guidelines "contradict the statutory provisions under which they were enacted," and therefore the federal government lacked the proper authority to implement them. The appellants took the view that the Guidelines:
"[5] ... do not appropriately reflect the requirements of the Divorce Act, which mandate that [child] support is a joint spousal obligation and is to be based on the relative ability of the spouses to contribute to the support of the children of the marriage. [They] argue that the Guidelines overcompensate the former spouses where there is a joint custody arrangement and the children reside part of the time with the payor parent."
One of the appellants signed an interim child support agreement and sought to lower the amount of his payments. Another appellant was making voluntary payments of child support which were calculated under the Guidelines. Another appellant was paying child support to one spouse as a result of an arbitrator's award and child support to a second spouse as a result of a court order. Another appellant was receiving child support and agreed that the amount should be lowered.

The reasons from the Federal Court don't tell us much more about the appellants' arguments than this, as the decision primarily concerns the federal government's application to turf the appellants' claim on the bases that the appellants aren't apply to make their claims, that their claims are no more than roundabout ways of attacking orders they don't like and that their claims are abuses of process. The court allowed the federal government's application, and it is this decision which the appellants have successfully brought to the Supreme Court of Canada.

Ultimately, this appeal is of primary importance as a result of the Federal Court's view on whether the appellants had the right to challenge a federal regulation, however if the Supreme Court of Canada allows the appeal, it will be very interesting to see what becomes of the challenge to the Child Support Guidelines when the claim is finally heard.

My thanks to Eugene Meehan's Supreme Advocacy newsletter for alerting me to the success of this leave application.

14 June 2014

Court of Appeal Issues Decision on Vexatious Litigation

The British Columbia Court of Appeal has just released its decision in Extra Gift Exchange Inc. v The Owners, Strata Plan LMS3259, in which the court summarizes and applies the case law on when someone can be declared to be a vexatious litigant.

This issue is important because serious consequences can follow from a judge's decision that someone has repeatedly started frivolous lawsuits. Under s. 18 of the Supreme Court Act, the court can make an order that someone not start a lawsuit in either the Supreme Court or the Provincial Court without permission from the court:
If, on application by any person, the court is satisfied that a person has habitually, persistently and without reasonable grounds, instituted vexatious legal proceedings in the Supreme Court or in the Provincial Court against the same or different persons, the court may, after hearing that person or giving him or her an opportunity to be heard, order that a legal proceeding must not, without leave of the court, be instituted by that person in any court.
Section 29 of the Court of Appeal Act says pretty much the same thing:
If, on the application of any person, a justice is satisfied that a person has habitually, persistently and without reasonable cause commenced vexatious proceedings in the court, the justice may, after hearing that person or giving that person an opportunity to be heard, order that proceedings must not be brought or commenced in the court without leave of a justice.
(Making things even better — or even worse, depending on your perspective — s. 221(1) of the new Family Law Act says that a judge can make an order:
A court may make an order prohibiting a party from making further applications or continuing a proceeding without leave of the court if satisfied that the party
(a) has made an application that is trivial, 
(b) is conducting a proceeding in a manner that is a misuse of the court process, or 
(c) is otherwise acting in a manner that frustrates or misuses the court process.
Under s. 221(2)(c), the judge can also order that the person pay the expenses of another party resulting from this sort of misbehaviour, pay up to $5,000 to someone affected by the person's conduct or pay a fine of up to $5,000.)

Of course it's not at all clear what it means to start "vexatious" lawsuits "habitually," "persistently" and "without reasonable cause." (You can get a sense of some of the confusion on this issue from the comments to my posts "Litigation Conduct may Constitute 'Family Violence' under the Family Law Act" and "Supreme Court Releases Decision on Vexatious Litigants.") And this is why the common law function of the courts is so important: it's their job to decide how many times you have to do something to be "persistent" or "habitual," how much of a dog your case has to be to be brought "without reasonable cause" and how pointlessly irritating your conduct has to be to be "vexatious."

The Court of Appeal was dealing with a real doozy in Extra Gift Exchange, which essentially concerned a series of disputes between someone who'd bought a unit in a mall in Richmond and the strata company responsible for managing the mall and the behaviour of the unit owners. The litigation had gone on for about 13 years before getting to the Court of Appeal on the vexatious litigation issue, and involved 15 different lawsuits, mostly started by Extra Gift Exchange, that had resulted in five appeals. However, the circumstances of the present appeal are less important than the court's discussion of the law, which really boil down to a recapitulation of the Ontario High Court of Justice's 1987 decision in Re Lang Michener et al. v Fabian et al.

The court in Re Lang Michener decided that the following seven factors need to be considered when a judge is deciding whether "a person has persistently and without reasonable grounds ... instituted vexatious proceedings in any court," the test set out in the Ontario legislation (secret decoder ring translation in italics):
"(a) the bringing of one or more actions to determine an issue which has already been determined by a court of competent jurisdiction constitutes a vexatious proceeding;
(Starting a lawsuit about a problem that a court has already decided may be vexatious;)
"(b) where it is obvious that an action cannot succeed, or if the action would lead to no possible good, or if no reasonable person can reasonably expect to obtain relief, the action is vexatious;
(starting a lawsuit that is obviously doomed to fail may be vexatious;)
"(c) vexatious actions include those brought for an improper purpose, including the harassment and oppression of other parties by multifarious proceedings brought for purposes other than the assertion of legitimate rights;
(starting a lawsuit just to harass someone, not because you have a genuine problem, may be vexatious;)
"(d) it is a general characteristic of vexatious proceedings that grounds and issues raised tend to be rolled forward into subsequent actions and repeated and supplemented, often with actions brought against the lawyers who have acted for or against the litigant in earlier proceedings;
(recycling the same complaints and problems in lawsuit after lawsuit suggests that the litigation is vexatious;)
"(e) in determining whether proceedings are vexatious, the court must look at the whole history of the matter and not just whether there was originally a good cause of action;
(the court should look at everything that has gone on in the litigation to date, and not just look at whether the original lawsuit was reasonable, to decide if the litigation is vexatious;)
"(f) the failure of the person instituting the proceedings to pay the costs of unsuccessful proceedings is one factor to be considered in determining whether proceedings are vexatious;
(failing to pay court-ordered costs suggests that the litigation is vexatious; and,)
"(g) the respondent's conduct in persistently taking unsuccessful appeals from judicial decisions can be considered vexatious conduct of legal proceedings."
(bringing lots of losing appeals suggests that the litigation is vexatious.)
The court added three points to Re Lang Michener:
  • applications to extend time and other procedural applications in appeal proceedings won't usually suggest that the litigation is vexatious; 
  • the Court of Appeal can look beyond the appeal and consider a litigant's conduct in the trial court to decided whether the litigation is vexatious; however,
  • there must be some misconduct in the Court of Appeal and the frequency of appeals in the Court of Appeal must be vexatious.
Returning to Extra Gift Exchange, the court decided that aspects of how Extra Gift Exchange managed the litigation suggested that the litigation was vexatious (important bits in bold, as always):
"[42] In the Supreme Court, [Extra Gift Exchange] have demonstrated many of the hallmarks of vexatious conduct that were described in [Re Lang Michener]:
· They have demonstrated a propensity to re-argue issues that have been decided against them
· They have brought multiple proceedings of dubious merit replete with unsubstantiated allegations of conspiracy and fraud, that could be described as harassment of the applicants. 
· The proceedings seem to roll forward and duplicate proceedings that have already been dismissed or struck. 
· Their pleadings have been described as prolix and unintelligible
· There remain outstanding costs orders."
However, despite these seemingly damning conclusions, the held that:
"[44] I cannot conclude that the conduct in this Court, even informed by their conduct below, has yet risen to the level necessary to grant the order sought. My primary reason for saying so is that the frequency of appeals simply cannot be said to be vexatious. I acknowledge that the appeal in this case appears to have little merit and the factum is difficult to understand. But nevertheless, without a stronger pattern of abusive and vexatious conduct in this Court, I am unable to grant the order sought. I have some considerable sympathy for the position of the Strata. They may of course renew this application should [Extra Gift Exchange] conduct themselves in this Court in a vexatious manner. But so far [Extra Gift Exchange's] conduct does not reach that exceptional level that would merit limiting their access to this Court."
Although this decision was sure to disappoint the strata company, the court did note that other remedies were available to it, such as applying for an order that Extra Gift Exchange be require to pay money into court to make sure that funds are set aside to cover any costs order made against Extra Gift Exchange.

Ultimately, Extra Gift Exchange is less than helpful in clarifying readers' questions about how many times you have to do something to be "persistent" or "habitual," how bad your case has to be to be brought "without reasonable cause" and how pointlessly irritating your conduct has to be to be "vexatious." All we know is that the degree of your misbehaviour must be "exceptional," and that you should bear in mind the seven factors described in Re Lang Michener.

However, from a family law perspective, it helps to remember that the language used in s. 221 of the Family Law Act is different from the language of s. 18 of the Supreme Court Act or s. 29 of the Court of Appeal Act. What s. 221(1) talks about is:
  • applications that are "trivial;"
  • "misuse of the court process;" and, 
  • behaving in a manner that otherwise "frustrates or misuses the court process."
None of these three reasons for asking for an order that someone not make further applications or continue a lawsuit use the troublesome language found in the court acts, and it seems to me that Extra Gift Exchange may not apply to applications under s. 221 of the Family Law Act at all. When the legislature uses different language to discuss a similar concept in different laws, it's presumed to having a reason for doing so, and one obvious reason would be to make orders under s. 221 easier to get than orders under the court acts.

I should also say something about the other remedies the court talked about in Extra Gift Exchange. The Family Law Act is full of useful orders that the court can make to modify litigants' behaviour, including these:
  • under s. 223(1)(a), the court can dismiss all or part of a lawsuit or an application;
  • under s. 223(1)(b)(ii), the court can delay a lawsuit until someone obeys an order;
  • under s. 244(1)(a), the court can require parties to attempt to resolve their dispute outside of court; and,
  • under s. 227(a), the court can require someone to pay money into court as security for the person's good behaviour.
Although it can be terribly difficult to get an order declaring someone to be a vexatious litigant, as Extra Gift Exchange shows, the Family Law Act provides a number of useful tools that might accomplish something approaching the same result and ought to be easier to obtain.

09 June 2014

Number of Stay-at-Fathers on the Rise: US Study

The Pew Research Center, an American think tank based in Washington DC, has just published an important new study, "Growing Number of Dads Home with the Kids: Biggest Increase Among those Caring for Family" (PDF) comparing demographic data obtained in 1989 and 2012.

Although the study is an easy read and clocks in at a modest 15 pages, here are the highlights of their findings:
· Fathers made up 16% of all stay-at-home parents in 2012, up from 10% in 1989. These fathers said that they are mainly at home because:
· they are ill or disabled (35%, down from 56% in 1989), 
· they cannot find a job (23%, up from 15% in 1989), and 
· they are caring for their home or family (21%, up from 5% in 1989).
· At-home fathers are twice as likely to lack a high school diploma than fathers working outside the home. 
· 47% of at-home fathers are living in poverty, compared to 34% of at-home mothers. 
· 50% of at-home fathers have a working spouse, compared to 68% of at-home mothers.
The Center also polled the views of the public on stay-at-home parents:
· 51% said that children are better off if their mother is home and doesn't have a job, compared to 8% who said that children are better off if their father is at home and doesn't have a job. 
· 34% said that children are just as well off if their mothers work, compared to 76% who said that children are just as well off if their fathers work.
On the whole these results aren't too terribly surprising. They reflect traditional social expectations of the different household roles played by men and women, but also that these values are beginning to soften, with more fathers being stay-at-home parents and more of those fathers choosing the role in order to care for family. It would be interesting to look at the extent to which this trend correlates with women's economic opportunities and employment incomes.