Hair Strand Testing – some interesting information

Photo : lab stuff courtesy of iTc on Flickr - thanks!

Hair strand testing of parents (and other family members) is relatively common in family court cases, especially care proceedings. Most judges, and social work and legal professionals working in this field are therefore used to reading the now lengthy reports that are produced by drug testing companies, setting out and analysing the results. Over the years these reports have become increasingly lengthy due to the increasing amount of standard explanatory “blurb” that needs to accompany the bare result to assist with interpretation and in understanding the proper limits on the testing science. There is an evaluative element to hair strand testing, particularly in cases of suspected excessive alcohol use, and it is important to be aware on what the science is and is not capable of telling us and how probative an apparently positive result really is.

In a recent case Lextox reported as follows (the Family Court has given permission for this extract to be published in anonymised form).

Q : The donor of these results has afro-caribbean hair. Is the growth rate of this type [of] hair slower than other types of hair? Would slow growth of this particular type of hair affect the time it would take to show a negative result or have any other impact on the tests results?

When assigning time periods, Lextox use an average growth rate of 1 cm per month as per the guidance from the Society of Hair Testing (SoHT). However it is an average growth rate meaning that in some people hair can grow at faster or slower rates (With a distribution generally between 0.6cm – 1.4cm per month). In addition, the time periods calculated assume that the hair was cut as close to the scalp and as straight to the scalp as possible. Due to the very curly nature of Afro Caribbean hair, this can make cutting the sample close to the scalp difficult. Therefore the time periods are quoted as approximate and should not be over-interpreted.

It is my understanding that Afro Caribbean hair grows at a slower rate than Caucasian hair. A 1 cm section of Afro Caribbean hair may therefore cover longer than the assigned 1 month time period. If [the subject’s] hair has a slower than average hair growth rate then the levels detected would be unaffected however the time covered by the hair analysed would be longer.

It is possible for a donor to provide a positive hair test result for approximately 3-4 months following cessation. This is because with Caucasians approximately 85% of scalp hair is growing at any one time, with the remaining approximate 15% in the resting (non-growing) phase. When an individual has regularly used a drug for example cannabis, stops and continues to abstain from using the drug it usually takes approximately 3-4 months for a person to return a “Not Detected” result. This is because the resting phase of the hair usually last [sic] 3-4 months. As the resting phase consists of only approximately 15% of the hair the levels detected are expected to be at “low levels”. A large decrease would be expected after the first month once an individual stops using cannabis followed by smaller decreases until a “Not Detected” is obtained after 3-4 months.

It is also my understanding that Afro Caribbean hair can have a higher percentage of hair in the resting (non-growing) phases. If this was the case, although it may not take longer to see a not detected result, the decrease in levels may not be as large as seen with Caucasians.

The usual blurb that this firm uses is as follows (I’ve not included all of it, just the bits that seem relevant to this issue):

Normal hair growth is a cycle composed of three stages, active growing (Anagen phase), transition (catagen phase) and a resting stage (telogen phase). There are significant differences in the relative proportions of actively growing hair and resting hair between different areas on the body. Scalp hair has been selected as a test specimen as it grows at a reasonably constant rate, ranging from between approximately 0.6-1.4cm per month with a population average of 1cm per month, and approximately 85% is actively growing (Pragst & Balikova, 2006) (Harkey, 1993).

…the time periods are approximate and calculated with the following assumptions :

  • The donor has a growth rate of 1cm per month
  • That the hair sample was cut as close to the scalp as possible
  • That the hair sample was cut straight with the scalp

A variation in any factors detailed above will affect the approximate time period calculated. …it can take approximately 2 weeks for hair to have sufficiently grown above the scalp to be available for inclusion within a cut hair sample…

When an individual stops taking a drug, it is still possible for low levels of drugs to be detected in a hair sample. This is due to the fact that at any one time approximately 15% of the hair is not actively growing. This hair would contain drugs that would have entered the hair during the period of drug use (Tsanaclis, 2007).

I asked for the extracted information above to be published because it seemed to me to be that although we all know (and are told in the blurb) that there are many caveats, assumptions and limitations to the interpreted results we receive, it is very easy to forget about the need to consider how the information contained in the report matches or jars with the other evidence in the case, before drawing conclusions. The extract highlights the fact that for a parent of Afro Caribbean extraction, there is a greater risk that the assumptions relied upon could lead to the court concluding that the subject has been untruthful about the date of cessation of drug use in circumstances where that was not warranted. There is of course a risk of this in all cases, because all hair growth rate assumptions are based upon an average, but the risk is by definition greater for those who are part of a subset of the population whose hair tends to grow more slowly, is more difficult to cut and test, and which has a tendency to have a higher proportion of hairs in the resting phase. It’s just a risk, but it is not one that is likely to have been actively considered in the absence of any warning in the blurb materials.

I asked Lextox about this extract and whether or not they were aware of any research papers specifically covering the differences between Caucasian and Afro Caribbean hair, and whether they were considering expanding or altering their general blurb to highlight the differences in hair behaviour and characteristics between different ethnicities. They have sent me this response, from which it appears that they consider their general blurb to be sufficient. They did not point me in the direction of any research studies, indeed they did not answer that particular question.

The use of hair testing in family courts is a well-established science in use across the UK in thousands of family law and child care cases annually. Lextox’s expertise lies in the detection of drugs, metabolites and alcohol markers in hair using highly specific and sensitive instrumentation accredited by the United Kingdom Accreditation Service (UKAS). Lextox experts are also members of the Society of Hair Testing (SoHT), an independent international body which provides guidance on appropriate analysis techniques for the detection of drugs, metabolites and alcohol markers in hair. By complying with the SoHT consensus, Lextox therefore provides hair analysis within internationally agreed recommendations.

Among those operating within these guidelines, it is well known that there are a number of assumptions when it comes to hair testing, particularly regarding the time period covered by the hair analysed. It is not possible to determine the exact growth rate of hair on a case by case basis for each individual donor. Therefore, a common assumption regarding hair growth rates is required for use in all cases in order to apply an approximate time period to the specific hair section analysed – this being that scalp hair grows at a reasonably constant rate, ranging from between approximately 0.6 – 1.4 cm per month, with a population average of 1cm per month.  

As such, when assigning time periods to a sample, Lextox uses an average growth rate of 1cm per month as per the guidance of the SoHT to calculate all time periods reported. The SoHT does not recommend that hair types from alternative ethnic backgrounds are treated any differently, although it is also documented generally that scalp hair from donors of Afro-Caribbean descent may grow more slowly, sometimes as slow as 0.5 cm per month. In our opinion this does not differ sufficiently enough from the extreme ranges of Caucasian hair growth rate to have any significant effect on the testing procedures involved, and as such Lextox applies the guidance from the SoHT to calculate all time periods reported. This practice is standard within the industry.

With regards to the percentage of hair in the resting phase, again this cannot be determined on an individual basis, and can only ever be an assumption. As such, Lextox uses the percentages of growing and non-growing hair derived from scientifically published data to help in the interpretation of the analysis results.

In summary, Lextox assesses each hair sample submitted on an individual, case by case basis. Any hair sample that is deemed too curly to section into the requested sections, whether of Afro Caribbean descent or not, will not otherwise be sectioned and this information will be relayed back to the client with a number of options on how best to proceed with that particular sample. In such a case, the assessment is made purely in consideration of the physical nature of the sample submitted, as sometimes the hair is manageable by our suitably trained laboratory technicians to handle and accurately align, measure and section.  

In all cases if a client has specific questions on the analysis results, including those regarding growth rates and the growth cycle of hair, Lextox also considers these on a case by case basis and in doing so responds to all client and court related enquiries free of charge.

This statement (which I’ve quoted in full) refers to the Society of Hair Testing, of which Lextox are said to be members. I’ve no reason to doubt that, but unfortunately the SoHT website does not publish its members, which is surprising. And nor is there anything on their website which helps to illuminate matters. There is no mention of ethnicity or of different hair types in any of the material I can find on that site.

The “consensus” document referred to is on the site, and dates from 2004. It includes the simple line In general, head hair is estimated to grow at approximately 1.0 cm per month.” But otherwise nothing much of relevance to this issue. Read in context it appears this was originally agreed by the members of the society as long ago as 1997.

There is a 2011 “statement” which appears to be good practice guidelines. It includes this passage :

It is accepted that head hair grows at an average rate of 1 cm each month [12] and a sample cut from the posterior Vertex region of the head, close to the scalp is preferred as this region of the scalp is associated with least Variation in growth rates. The amount of hair required for analysis is a “lock of hair” or a pencil thickness of hair. It is important to collect sufficient hair in order to carry out routine tests and to allow for a repeat analysis or confirmation test by a second laboratory.

Concerns are often raised in relation to leaving a visible “bald patch” of particular concern with small children or individuals with baldness or thinning hair. In these cases, collection of several smaller hair samples from multiple Sites, focusing where possible around the posterior Vertex region is acceptable.

Head hair is the preferred sample, however, if head hair is not available alternative collection sites should be considered including pubic, underarm and beard hair. Collection of intimate samples requires consideration for the privacy of the donor while ensuring that the integrity of the collection process is not compromised. Growth rates and dormancy characteristics of hair from these alternate sites, differs from head hair.

The reference [12] is to a 1993 paper : M.R. Harkey, Anatomy and physiology of hair, Forensic Sci. Int. 63 (1993) 9-18, (a time when hair strand testing was emergent, as far as I understand it – indeed the SoHT was founded in 1995).

None of the references to research papers that I can find on the SoHT OR appended to the standard blurb in Lextox reports appear superficially (i.e. based on their title) to relate to the issue of different characteristics of hair taken from particular ethnic groups.

I do not presently have the capacity to track down, pay for and read all of those references, or indeed to search for those not listed – so I may be wrong about this – but it is not entirely clear that there is very much good research about this issue at all, and I wonder (it is no more than that at present) whether when it is said that “it is also documented generally that scalp hair from donors of Afro-Caribbean descent may grow more slowly, sometimes as slow as 0.5 cm per month”, this may mean that this is anecdotally a known issue, but nobody has yet bothered to do any robust research on it.

When I have a moment I will send a copy of this blog post to the SoHT and ask them if there is anything relevant, and will update if and when any response is received.

If anybody has had cause to explore this issue or read the relevant papers in one of their cases I would be grateful for any further light that you can shed on this. I doubt in reality that I will have time to do much follow up any time soon given other commitments.


Feature Photo : lab stuff courtesy of iTc on Flickr – thanks!

Hear the angsty screams of the family lawyers…

i sort of feel obligated to vent on behalf of the family law community about The Archers – after all, the criminal bar have had their turn and have pointed out that it is now ours (see Matthew Scott in the Telegraph here and another piece here in the Guardian). Not that it stopped us pitching in whilst their field of work was chopped up and stuck back together to form some Frankenstein version of criminal process. But now we’re back in the Family Court and it’s not got any better…I’ve been masochistically listening to the podcasts this week, trying to find the time and the will to draw together this post.

So. Here goes. We’ll all feel better once I’ve got this out of our system….

The criminal trial finished last week. Handily, this has dovetailed with a completely free week in the family court where (also handily – or entirely inappropriately depending on whether you have two brain cells to rub together) the same judge is also knocking about with nowt in his list and has thought he might have a bash at the family matter and is sitting in the handily empty court room that is available this week. Another happy coincidence is the availability of the social worker to come and give evidence, who evidently didn’t have a dangerous caseload or an EPO or a risk averse manager breathing down her neck and so could pop to court at short notice to give the evidence that will clinche victory for the righteous Helen. Or maybe the judge in the family court thought it was a good idea to block out a whole week of family court time and block up counsel’s diary in the certain knowledge that the criminal trial would finish exactly on time and it would all seague seamlessly from one forum to the next with not so much as a broken video link to hold things up. Maybe…

Anyway, happily (everyone is VERY happy in The Archers at the moment, apart from Rob who is very not happy), as the same judge is dealing with it the need to obtain transcripts of the evidence for the benefit of the family court is completely done away with. Because it’s really absolutely fine for the criminal judge to just rely on his memory of the evidence heard in a different court for an entirely different purpose, where the father was not even represented (he was a witness) and where the witnesses and the questions were directed to entirely different things. And probably things like statements of evidence and schedules of allegations are an unecessary distraction since #webelieve Helen already.

Also fortunate is the fact that the social worker was able to give direct evidence of the father’s abusive behaviour sufficiently cogent for the judge to find the allegations proved on the basis of her evidence. Yay! I’m really very impressed with this social worker. Not only has she been entirely invisible up until now, but she has also apparently been hiding behind the arras the whole time, and witnessed these things happening. Which is handy, and avoids the court actually hearing direct evidence from the parties about these things, which would be very tiresome for the audience who already #webelieve Helen, who is righteous and should regain custardy of the children.

To be fair, we did hear a bit of evidence from Helen earlier in the week, just to give the script writers an opportunity to show Rob Titchener’s barrister having to pursue an excruciatingly crap line of cross examination that attempted to imply it was neglect for a mother to leave her child with his grandparents whilst she pops for a haircut…I mean, this is the stuff of which middle class thresholds are made isn’t it? Not his best point. Or possibly it was…

Fortunately everyone seemed to forget to ask any questions about anything actually important or helpful, like ooh, you know rape and hitting – because that would have been boring. And *yawn* we’ve heard that before. And like, a not guilty verdict on an attempted murder charge is like basically the same as innocent and is like totes the same as a finding of rape, okay? And this is the family court so we can just ignore the outrageous leading questions that gave rise to the allegation…or the timing of the allegation…Can someone remind me why we’re having this hearing at all? Oh yes, narrative arc. Sorry, forgot myself.

The other really amazing thing, and I guess this is probably down to the amazing modern technology that is so very very real in each of our courts – is that counsel for Mr Titchener, even though he wasn’t at court during the criminal trial, has all the papers already (by magic e-bundle or something – who needs disclosure processes?) and is able to be up to speed and ready to crack on first thing on Monday morning, and ready to drop massive clangers before the first wee break (mixing up the burden and standard of proof? Has anyone checked he made it to call?). But seriously, it’s very impressive of him to be able to conduct a defence of his client without knowing either exactly what the witnesses said last week or which particular bits the judge’s mind. Come to think of it maybe he doesn’t have the papers from the criminal trial – in which case he is even more of an impressive and fearless advocate. Hopefully with adequate BMIF cover in place. But I guess it probably wouldn’t be proportionate to adjourn for petty things like a fair trial so he might as well crack on…After all, WE all know his client is a basket.

So far so realistic…

What about the judgment though? Well, fortunately the judge does not repeat the error of counsel for Mr Titchener, about the burden and standard of proof. For judge Loomis is now in the family court and need not trouble himself with such points of detail…He bases his findings of fact squarely on the evidence of the social worker, who we all thought hadn’t met the mother until AFTER everything happened but presumably had a time machine, he moves straight from findings to welfare with not so much as the blink of an eye, and basically decides the case on the basis that “Rob is an unspeakable sh*t”. I mean, in such circumstances who needs actual reasons for disregarding the evidence of one party in favour of that of another (albeit one with magical time travelling fly on the wall powers)…I’m *pretty* sure the Court of Appeal would agree.

I’m sure that off-mic, in between all the hysterical snuffling and wailing (everyone is VERY happy in the Archers, apart from Rob who is very very unhappy, but also everyone is still a bit tired and emotional in the Archers too), the superlative Anna Tregorran reminded the judge he had forgotten to deal with Rob’s step-parent PR and that he expanded on his reasons for immediately terminating the relationship of a small boy with the person who has been caring for him for many months…

After the very realistic trial, the entirely brilliant Anna Tregorran tells her client that “You’ve won – you’re properly free”. I must have missed something because I’m pretty sure that the judge just ordered a psychological assessment in order to inform future decisions about contact with the baby, and that therefore the family are consigned to at least another four months of proceedings and ooh, about another 17 years of co-parenting. Plenty of opportunity to continue being an utter sh*t.

Also, I imagine that Helen and Rob will be superbly pleased to find out that that psychologist is going to cost them another five grand or so…On top of their already whopping legal fees. I hope that organic jam or whatever it is that they make is a real money spinner.

And by the way Anna, we NEVER tell our clients they win. Nobody wins. Anybody would think you weren’t a REAL family barrister! I bet she isn’t even in the Legal 500…

Jackson’s Thriller

Mr Justice Peter Jackson has broken twitter. Not with his bootlylicious bottom, but with his judgment in the case of Lancashire County Council v M & Ors [2016] EWFC 9 (04 February 2016), just published.

It begins by massively understating its brilliance and its near uniqueness :

This judgment is as short as possible so that the mother and the older children can follow it.

In fact, it isn’t short at all (although undoubtedly it could have been much longer if the judge had not been so disciplined and economical). But it is written for the benefit of the family – particularly the older children, but also the mother, who it appears remains vulnerable and implicity has some learning difficulties* – and no doubt the younger children in due course. It is beautifully, simply, and elegantly constructed – using normal everyday words to describe complicated legal concepts. 

So…. :

On threshold and the basis of state interference with family life :

Unfortunately, there have been some serious problems, ending up with the children being taken away and Mr A being arrested and kept in prison.

Children can’t be taken away from their parents unless social services prove to a judge that it would be harmful for them to live at home. If children are taken away, judges will always try to return them if that is safe.

Another thing is that children are not taken away from their parents simply because the parents have lied about something. Even if they do tell lies they can still be good enough parents.

People can tell lies about some things and still tell the truth about other things.

Also, children are not taken away because parents are rude or difficult or because they have strange views, even if those views offend people. The only reason to take children away is because they need protecting from harm.

The actual threshold facts in the case are reduced to four brief lines :

1 Problems at school

2 Mr A’s behaviour and the mother’s weakness

3 Mr A’s extreme views

4 The risk of Mr A taking the children to live outside England

with the relevant date elegantly explained and without all of that harm, or likelihood of harm, is attributable to the care given to the child, or likely to be given to him if the order were not made, not being what it would be reasonable to expect a parent to give to him” rubbish that is like a school test about double negatives and enough to make anyone’s head explode.

Even the Lucas direction is distilled :

People can tell lies about some things and still tell the truth about other things.

He tells the children that he has listened to everyone’s views. He explains his process and decision :

After thinking carefully about this and listening to everyone, I do not agree with Mr A at all. People are not out to get him. His problems are his own fault. … he is dangerous to the children and their mother because of the way he behaves and because the mother is not able to stop him. There is a good side to Mr A – everyone has a good side – and this makes it hard for H and A and their mother to see what he is really like.

Of the controlling relationship between the mother and Mr A he said this :

One reason why the problems have become so serious is that the mother and Mr A are so different. The mother is a quiet and peaceful person. She would like a happy home and for the children to do well at school. She wants to be loved. She is not interested in politics or religion and does not know much about what goes on in the world. She is not at all curious and often finds things hard to understand. In a day-to-day way she is a good mother and she certainly loves her children very much.

But there is more to being a parent than that. You have to make good plans for your children. You have to know what is right for them and be strong enough to try to make it happen. You have to protect your children from bad influences.

I’m afraid that in that way the mother has not been a good parent. She has been weak and foolish. She has allowed her feelings for Mr A to blind her to what he is really like. Even now, she is struggling to see what everyone else can see. She feels sorry for him and makes excuses for him. That is what Mr A wants her to feel. He has got inside her head and it will take time for her to recover.

Later he says that “She doesn’t seem to think that she had any say in whether he went or not, or how it affected the family. It shows how helpless she is.”

He says that

It is lucky that Mr A was arrested so that he was not able to go on with his plans to take the children out of England. That is why it is not safe for him to be in the children’s lives.

The mother has been very slow to realize this. It is extremely disappointing that she could not see it earlier. Before the trip, Mr A was interfering with her children’s upbringing but she did nothing to stop it. During the trip, she risked the children being kept abroad. After the trip, her lies meant that the children could not return home. By protecting Mr A, she also put them at risk of being smuggled out of the country. I hope that she now realizes how dangerous Mr A is to her and her children and how he has used her. The time for her to say that she does not understand that is over.

The CEO of Womens’ Aid yesterday complained on twitter (on her personal account) that “on the face of it (and I accept I don’t know the case) mother is being blamed for father’s abuse.” She said that “it shows v common blaming of mother and lack of insight into impact on her of fear and control exerted by father.” (Another said that the use of the word “weak” to describe the mother jarred.)

I disagreed at the time and said I would go back and look at the judgment again. I have. I still disagree. I think that “weak” has been used in place of the more difficult concept of “vulnerable”. I think that is a legitimate substitution. And I don’t think that in context the judge is blaming this mother for the conduct of Mr A, who he roundly condemns (there is a lot more severe and brutal criticism of Mr A in the judgment than I have included). What the judge does is to focus (as the law requires) upon the way in which the mother has (or has not) discharged her responsibility towards her children as a parent. When deciding whether the state should interfere with a family the law is interested in whether parents have in fact harmed their children through their parenting – not why. IF they have harmed them (through action or inaction) then the question of why becomes relevant – because IF they can change or be helped to change their parenting to prevent it happening in the future there would be no need to take children away. This judge has said that the mother is weak (vulnerable), she has made bad choices, she still finds good choices hard – but ultimately he did return her children (or allowed her to keep them?). That’s not victim blaming, it’s allowing a survivor her agency, and restoring her responsibility as a parent. Control can endure long after a relationship is over, but to place all responsibility for ever on the controller by insisting on a static binary of passive victim : active perpetrator is to freeze a victim as eternal victim and disempower and demotivate her from becoming a survivor, a decision maker, a person back in control. You cannot have control without responsibility. And ultimately I think that Jackson’s judgment is kind, humane. I reject any suggestion he does not display a good understanding of the dynamics of control. On the contrary I think he understands it very well. And he knows this mother will need reminding of the risks. It is why, in his judgment, he has given her a roadmap.

It is right that there is not a head on exploration of fear, but at paragraph 25 Jackson J sets out 13 paragraphs of all of the very, very frightening behaviour of Mr A towards professionals and in court. It is under the heading “Mr A’s behaviour and the mother’s weakness”. I think it is pretty clear this judge understands the power this man will have had over the mother, notwithstanding the fact that the mother’s own evidence did not appear to be about fear.

The final order made in this case were care orders, with a plan for the children to live with their mother and grandmother. From this it is apparent that there were probably residual concerns about the mother’s ability to continue making good decisions and to protect the children – but that rather than being blamed or penalised for her enduring vulnerability she is being supported in the exercise of her responsibility in future by her mother and the local authority. Surely this is a recognition of the enduring impact of control and of the mother’s own vulnerabilities?

The tweets I have seen about this judgment have been (apart from those minor cavils) ecstatic – from lawyers (in all fields), academics, judges, social workers, adopters, parents and all sorts of others. It should be used for judicial training, law student essays (write a judgment in the style of Lancashire CC v M), all judgments should be written like this…Heartfelt pleas for this to be standard practice, ponderings on why it isn’t…

Groundbreaking as it is, some reports have got a little over-excited : The Times report that the judge has included “a “smiley face” emoji to explain the evidence.” That in fact is not quite accurate – the judgment does include a smiley, but the smiley face emoji was a part of the evidence, so rather than the judge using an emoji to explain the evidence the judge just described that evidence, which happened to include an emoji (Written on a note by the mother). This is a bit like accusing a judge of swearing when he’s simply quoting a witness. I think we are still some distance from a modern system of binary findings that are described as either 🙂 or 🙁 ….

However, one can see that in this particular case it will potentially be really so important for the family to have this judgment as a core part of their narrative, of the children’s life story – no doubt it will have significant protective power to keep this family on the straight and narrow – to help keep the mother strong. But apart from the specifics of this case, all children, all parents, should have this. And that does not just mean the production of a transcript of a judgment that mechanically trogs through the statute, the evidence heard, a “holistic evaluation” and a decision – a document that will be utterly unpenetrable in years to come to any family member who may read it. This judgment was laboriously written, each word and phrase carefully chosen, so it would be legally correct and meaningful to this family. Each word does a job.

It is very hard and very time consuming to write this way. It is the way I try to write when I write The Family Court without a Lawyer (and yes, before you make any sarcastic comments it is a discipline I usually gleefully abandon when blogging). At the end of each phrase, I ask – is there a cleaner way of saying that? A way that is less likely to inadvertently confuse? There usually is. It is a skill and a discipline that can be learnt and it is not only judges who should practice it, but we lawyers should do so as well – when we speak in court about learning disabled parents who are present, and even when we speak in court about parents with no particular cognitive difficulty – we should speak their language the first time round, rather than translate it hastily after the hearing. I’ve had a few cases where I’ve drafted child friendly orders, or have assisted with the wording of letters to the children, and others where I’ve asked for certain matters to be recorded in judgments for life story purposes. We should do more talking to families on their own terms, recording their lives in ways they can access when they are ready, like a treasured photo album which contains sometimes sad but always important memories.

If only Jackson J could have written the script for The Archers, we could perhaps have had good writing AND legal accuracy. Sadly that seems to have flown out of the window even more as the “custody” battle resumes in the Family Court tonight… Of which more in another post.



*see judge’s description of her here :

The mother is a quiet and peaceful person. She would like a happy home and for the children to do well at school. She wants to be loved. She is not interested in politics or religion and does not know much about what goes on in the world. She is not at all curious and often finds things hard to understand. In a day-to-day way she is a good mother and she certainly loves her children very much.