[154] The case law has recognized that persons who hold certain attributes may be more likely to impair a child’s opportunities for adoption, as these attributes might dissuade adoptive applicants from coming forward to adopt the child. This might result in an undue delay in the child’s adoption. Many people will hold more than one of these attributes. (a) The first attribute is a difficulty with aggression, anger or impulse control. Persons with this attribute are often confrontational. This attribute may threaten the physical or emotional security of the adoptive parents and their family. (b) The second attribute is a lack of support for an alternate caregiver of the child. This might manifest itself in an undermining of the adoptive placement and the child’s sense of security with the adoptive family. Persons with this attribute may be relentlessly critical of the adoptive parents and make their lives very difficult. They are usually unable to accept their reduced role in the child’s life. (c) The third attribute is dishonesty and secrecy. Persons with this attribute can often not be trusted to comply with the terms of court orders or to accurately report any important issues about the child. (d) The fourth attribute is a propensity to be litigious. Persons with this attribute are usually unable to accept a reduced role in the child’s life and are likely to engage in openness litigation. See: Children’s Aid Society of Toronto v. A.F., 2015 ONCJ 678.
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