In Moyer v. Douglas [2007] W.D.F.L. 1924 (S.C.J.), parallel parenting was ordered. Communication problems were not seen as an obstacle because cooperation was not a prerequisite to each parent making decisions, nor the parents carrying out his/ her parental responsibilities. Further, parallel parenting was not made with the hope that parenting skills would improve, but with a recognition that both parties had adequate parenting skills.
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