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Carlisle Family Court Orders Foster Care for Child Amidst Parental Manipulation Concerns: Re M (A Child) [2023] EWFC 312

In the case Re M (A Child) [2023] EWFC 312, the Family Court at Carlisle, presided over by His Honour Judge Baker, ordered that a seven-year-old girl, referred to as Mary, be placed into foster care due to significant concerns regarding emotional manipulation by her biological mother, Bethany. The judgment reveals a troubling history of Bethany's resistance to court orders and her efforts to undermine the child's relationship with her psychological parent, Alice, who had been Mary's primary carer for several years.

The court found that Bethany's actions, including the use of social media to post distressing videos of Mary, constituted severe emotional harm and manipulation. This behavior was consistent with earlier psychological assessments that highlighted Bethany's personality traits, including histrionic and manipulative tendencies. Given the drastic shift in Mary's expressed wishes, which coincided with increased unsupervised contact with Bethany, the court concluded that foster care was necessary to protect Mary's emotional and psychological well-being.


Case Overview:

  • Case Name: Re M (A Child) (No. 1) [2023] EWFC 312

  • Court: Family Court at Carlisle

  • Judgment Date: 13 April 2023

  • Judge: His Honour Judge Baker

  • Key Parties:

  • Applicant: Alice (Psychological Parent)

  • First Respondent: Cumbria County Council

  • Second Respondent: Bethany (Biological Mother)

  • Third Respondent: Children's Guardian (Mr. Moray)

Legal Issues:

The case centered around the emotional and psychological safety of a child, Mary, caught in a high-conflict situation between her two parental figures. The court had to balance the potential harms associated with removing Mary from her biological mother's care against the risks of continued emotional manipulation and alienation from her psychological parent, Alice.


Court’s Analysis:

Judge Baker meticulously reviewed the case's history, including previous psychological assessments that described Bethany's manipulative and histrionic personality traits. The judge found that Bethany's recent behavior, particularly her use of social media to publicly broadcast Mary's distress, posed a significant emotional risk to the child. Despite the serious implications of placing a child in foster care, the court determined that it was the only viable option to safeguard Mary’s well-being.


Judgment Summary:

The court ordered that Mary be placed into foster care under the supervision of Cumbria County Council. This decision was deemed necessary to protect her from the ongoing emotional harm caused by Bethany's actions. The court also expressed concerns about the rapid shift in Mary's expressed wishes, which suggested that Bethany's influence was detrimental to the child's psychological health. The placement in foster care was seen as a temporary but essential measure to provide Mary with a neutral environment while further assessments were conducted.


Keywords:

  • Re M (A Child) [2023] EWFC 312

  • Carlisle Family Court judgment

  • Foster care order

  • Emotional manipulation

  • Parental alienation

  • Psychological assessment

  • Child welfare

  • Family law

  • Section 91(14) Children Act 1989

  • Cumbria County Council


Special Considerations:

This case highlights the complexities in family law where issues of emotional and psychological manipulation are involved. It underscores the importance of timely and thorough assessments to protect the best interests of the child, even when such actions involve difficult and painful decisions like removing a child from a parent's care.

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