UPPSALA 1979

My first experience of the International Society of Family Law (ISFL) was the third World Conference, held in Uppsala, Sweden in 1979, which I attended together with my colleague at the University of Bristol, Gillian Douglas. I had never been to an ISFL World Conference before, and I was excited by the prospect – and I was not disappointed. For me, it remains one of the best and most stimulating international conferences I have attended. The theme of the conference was ‘Cohabitation’, which in those days was regarded as being very ‘avant-garde’, but then, this was Sweden after all. Indeed, I recall one of the sociological papers was on ‘deviant behaviour’, and examined, in particular, jurisdictions in which, because of its incidence, cohabitation had become ‘normative’ as opposed to ‘deviant’ behaviour. Another memorable paper was one given by Eric Clive, who argued that marriage could be jettisoned as a legal concept (aliter a religious one) in favour of one based on cohabitation. Food for thought indeed!

I remember, too, being impressed and not a little overwhelmed by a scholarly paper presented by a German academic examining English common law. I was clearly going to have to ‘up my game’ if I was to perform on the world stage.

Amongst the myriad of stars that attended and presented at Uppsala, one stood out above the rest – Mary Ann Glendon. Not only did she give a fascinating paper, but on one occasion she considered the English simultaneous translation of a paper given in French to be inadequate. She offered to take those who wanted to to a separate room, where she gave a seminar on what the speaker was trying to say. Sadly, that was the only occasion that I came across Mary Ann.

The conference, of course, was not without incident – I remember one in particular. After a German scholar had made his presentation in English, he was asked a question, to which he turned to the German-speaking Chair and answered in German. The Chair translated his answer into English.

1. INTRODUCTION

It is a privilege to write in honour of John Eekelaar, whose contribution to the study of family law is as immense as it is wide-ranging. Aside from his research, John was a key figure in creating and nurturing the International Society of Family Law, which was so influential in shaping the family law agenda, and which provided opportunities for academics around the world to meet and to discuss issues of joint concern.

I first met John in 1976, at a conference organised by the University of Toronto. He was already an established and well-respected scholar. I had just ‘discovered’ the issue of international parental child abduction via my research into the wardship jurisdiction. John also had an early interest in that topic, and his valuable study of the problem, in Commonwealth legal systems, helped to persuade Commonwealth law ministers to support a Hague initiative, which in due course led to the concluding of the 1980 Hague Abduction Convention.

While John’s career took a different direction, I developed an interest in international child abduction and, more broadly, in the global attempts to deal with cross-border disputes concerning children. Pursuing an international theme, this contribution explores some of the jurisdictional consequences that ensue in having to apply the 1996 Hague Protection of Children Convention (the Convention), rather than Council Regulation No. 2201/2003 (the revised Brussels II Regulation, hereafter ‘BIIa’), which the UK formally revoked on 31 December 2020 – the end of the implementation period following its withdrawal from the EU – and which is now referred to as ‘IP completion day’.

2. BACKGROUND TO THE CURRENT JURISDICTIONAL RULES

2.1. THE CONVENTION, BIIA AND THE FAMILY LAW ACT 1986

Jurisdiction to make orders relating to children is complicated. To put the following discussion into context, it should be appreciated that, before IP completion day, the UK was bound by BIIa, and was a Contracting State to the Convention. So far as children are concerned, the two instruments overlap to a significant extent, which is not surprising, since the Regulation was modelled on the Convention. Each instrument provides for common rules of jurisdiction, and for consequent recognition and enforcement.

INTRODUCTION

In mid-2018 England and Wales had an estimated population of 59,115,800, of which 12,584,403 (21%) were children aged 0 – 18 years. In 2017 there were 101,669 divorces of opposite-sex couples in England and Wales (the lowest since 1973), 338 divorces of same-sex couples, and 1,217 dissolutions of civil partnerships. Between 2008 and 2018 5 there was a 25.8% increase in the number of people who live together as a family without being married to each other, making this the fastest-growing family type in England and Wales and, indeed, the UK as a whole. Given that there is an increased likelihood that such families will break down as against married couples, the fact that there are less divorces does not necessarily mean there are less family breakdowns. Although there are no statistics on the breakdown of family relationships outside marriage or civil partnership, it is clear that the 3.9 million children who are part of the 2.5 million separated families in England, Wales and Scotland are directly impacted by the decision-making processes which take place about their post-separation care arrangements. If those with parental responsibility for the children are unable to agree what these arrangements should be, the decisions will be made through agreement in mediation or some other form of dispute resolution, or by the court in judicial proceedings.

England and Wales has a Family Court which deals with all family cases, including all those concerning the upbringing and status of children except those invoking the inherent jurisdiction of the High Court and international cases concerning applications relating to child abduction and matters of jurisdiction, recognition and enforcement under the 1996 Hague Protection of Children Convention. These latter cases are heard by the Family Division of the High Court. Whenever a court decides an issue relating to a child's upbringing, its paramount consideration is the child's welfare.

STATUTORY PROVISIONS

DOMESTIC PRIVATE CHILD LAW PROCEEDINGS

There is no mandatory provision governing children's participation in domestic private child law proceedings. However, by section 1(3)(a) Children Act 1989, the court must have regard to the ‘ascertainable wishes and feelings of the child concerned (considered in the light of his age and understanding)’. The Act is silent on how these wishes and feelings should be ascertained.

INTRODUCTION

This chapter explores the reception and influence of EU family law legislation and approaches on family law in the UK with particular reference to England and Wales, and considers whether there is a differentiated approach to legislation affecting adult relationships as compared with that directed at children.

For the purposes of this discussion, we concentrate on the EU instrument that the UK has opted into, namely the revised Brussels II Regulation (hereinafter ‘BIIa‘), as against those which the UK has not opted into, namely the Rome III Regulation (hereinafter ‘Rome III‘) and the regulations concerning matrimonial and registered partnership property regimes. Some reference will also be made to the Succession and Maintenance Regulations.

BIIa deals both with matrimonial matters, that is, divorce, legal separation and marriage annulment, and with civil matters relating to the attribution, exercise, delegation, restriction or termination of parental responsibility. In the former case, it provides rules on jurisdiction and recognition of divorces, etc. In the latter case, it provides rules on jurisdiction, recognition and enforcement of judgments on matters of parental responsibility. In addition, it supplements the provisions of the 1980 Hague Abduction Convention as between EU Member States by providing a number of rules to tackle child abduction and facilitate the child‘s return, and, inter alia, deals with the placement of a child in another Member State.

Rome III regulates jurisdiction and introduced rules concerning the applicable law in matrimonial matters. The growth in cross-border couples or couples from one Member State residing in another Member State following the free movement principle posed problems not only on which jurisdiction could or should be seised when such couples divorced, but also on the applicable law. Rome III does not set out to harmonise the divorce laws of Member States; rather, its aim is to achieve greater certainty and predictability about which Member State‘s divorce law would apply by providing both party choice and uniform rules. However, given the lex fori approach in the UK which automatically applies domestic law where a court has jurisdiction, the need for the UK courts to apply the divorce law of another jurisdiction proved to be a step too far.

INTRODUCTION

At the 6th CEFL Conference on Plurality and Diversity of Family Relations in Europe, the draft of the Principles of European Family Law Regarding the Property, Maintenance and Successions Rights of Couples in de facto Unions was presented. The day before the conference, this draft had been discussed at great length with CEFL's Expert Group, whose members had prepared the national reports. In the following we will provide a brief overview of the draft.

THE GENERAL APPROACH

2.1. METHOD

Based upon a questionnaire containing 74 questions, CEFL's experts drafted 29 national reports. The questions addressed a few general issues (legal sources, historical developments and law reforms), statistics and estimations, issues that arise during the relationship, separation and death, as well as agreements between the partners and, finally, disputes. The comparative material was compiled in a book that was published in 2014. The drafting of the Principles took place at eight meetings of CEFL's Organising Committee, comprising seven members, four of whom are the authors of this contribution, plus Frédé rique Ferrand (Lyon), Maarit Jänterä -Jareborg (Uppsala) and Velina Todorova (Sofia). At these meetings the Principles were formulated, the relevant international and European instruments were analysed, the comparative overviews with references to all national reports were drafted and the comments which explain the Principles were designed and discussed.

2.2. STRUCTURE

The fifth set of CEFL's Principles of European Family Law consists of 27 Principles contained in seven chapters. The structure of the new set of Principles is comparable with previous sets of Principles. They start with a Preamble, followed by the first chapter on definitions and the scope of application. General rights and duties are then addressed. Agreements, property and debts, separation, death and disputes are the titles of the subsequent chapters.

2.3. TERMINOLOGY

During the drafting process of the Principles the terminology was changed. Initially, in the questionnaire and the publication of the national reports, the term ‘informal relationship’ was used. The term ‘informal’, however, is just the opposite of ‘formal’, which indicates marriage and registered partnerships and the like. More importantly the term ‘informal’ suggests that there is a lesser commitment by the persons involved, which, however, cannot be assumed.

INTRODUCTION

Chapter II of the CEFL's Principles of European Family Law Regarding Property Relations Between Spouses deals with what is entitled ‘Marital Property Agreements’ by which is broadly meant agreements made before or during the marriage determining the spouses’ property relationship. Insofar as statistics are available, the evidence is that the number of such agreements has become more frequent.

SOME BASIC DILEMMAS

In drawing up these Principles it was sought, on the one hand, to promote spousal autonomy and, on the other, to balance the freedom to make agreements with the need to give fair protection to each spouse and to third parties. Spousal autonomy has been a guiding philosophy underlying all the CEFL's Principles, as can be seen in its Divorce Principles, whichessentially promoted divorce by consent with little or no State interference depending on whether there are children under the age of 16 and, more particularly, in its Maintenance Principles, according to Principle 2:10 of which, spouses are permitted to make maintenance agreements again subject to minimal State scrutiny. But unbridled freedom to make marital property agreements could lead to injustice and the CEFL has sought to balance that freedom against the important general purpose of matrimonial property law to grant each spouse the right to obtain a fair share in the property of the other and to give fair protection to third parties against fraudulent manoeuvres.

To achieve this balancing act, the Property Principles provide in the first instance for the basic freedom to make martial property agreements but nevertheless require such agreements to conform to certain conditions as to form and disclosure. The Principles also prescribe the obligations of notaries or other persons with comparable functions; set out the effects of such agreements against third parties and, consistently with other Principles on distribution (that is Principles 4:32 and 4:57) and Principle 2:6 of the Maintenance Principles, empower a competent authority to set aside or adjust the agreement in cases of exceptional hardship.

Introduction

This chapter explores how, and to what extent, the three generations in our group of divorced families communicated with each other about marriage breakdown and its consequences. First, it looks at the way that parents warned their own parents about their impending separation, and then investigates what the grandchildren told their mothers, fathers and grandparents about their relationships with the ‘other side’ of their divided families. The chapter also investigates whether or not children were used as conduits for the flow of information between the two sides of the divorced family.

Telling grandparents about the planned separation

Although grandparents were not asked directly when and how they were told about the breakdown of their child’s marriage, the interview guide included questions about their relationships with grandchildren before and after the separation. Almost half the grandparents interviewed mentioned their surprise at learning of their child’s separation. It was common for parents to hide their marriage problems from their own parents and the news of the separation often came as a shock to grandparents. Parents admitted that they were reluctant to take grandparents into their confidence, but their explanations made it clear that this was neither symptomatic of a lack of affection nor a failure to anticipate the likely effects of their separation on the wider family. A rather similar conclusion, it may be recalled, was made as a result of the investigation of children’s reluctance to confide in their grandparents when they felt upset or worried about family break-up (see Chapter Three).

The deliberate concealment of problems might be interpreted as evidence that parents did not consider grandparents to be involved. However, divorced couples were also concerned about disappointing their parents; they were worried about invoking their displeasure and anxious to protect them from the pain of their divorce – feelings that are characteristic of many parent–child relationships. The interview data revealed that most mothers had worried needlessly and were pleasantly surprised by their parents’ reactions to being told that the marriage had ended. For example, Alfie’s mother recalled:

A changing relationship

In Chapter Two, we discussed some of the factors that previous studies have indicated influence the nature of grandparents’ relationships with their grandchildren. In this chapter, we ask: ‘What importance do grandchildren attach to their relationship with their grandparents and how might these relationships be affected by divorce? And, ‘is there evidence of continuity in the grandparent–grandchild relationship in divorced families as well as evidence of change as the result of family break-up?’.

Grandparent’s relationships with their grandchildren

The studies reviewed in Chapter Two made it clear that grandparent age is related to the frequency of grandparents’ contact with their grandchildren and that older grandchildren have less contact with their grandparents. But does this mean that they are not as emotionally close to their grandparents? Here, we begin by considering the views of some teenage grandchildren and their feelings about their grandparents. They reported that they have close relationships with their grandparents, but this assertion was often accompanied by apparently contradictory evidence of a growing emotional distance. Being ‘close to grandparents’ could mean seeing them regularly, enjoying their company, sharing intimacies and expressing affection. However, we discovered that the phrase need not imply anything about frequency of contact and was used on occasion to mean ‘nurturing positive feelings’. Evidence from divorced parents suggested that older grandchildren saw their grandparents less frequently than their younger brothers and sisters. Mothers, we discovered, occasionally reminded their children that they had not seen their grandparents for some time and persuaded them to accompany them on a visit to their grandparents’ home. They reported a gradual reduction in their children’s contact with their grandparents. Most felt that this did not mean that relationships could no longer be described as ‘close’ or that grandchildren and grandparents felt less affection for each other. It was, in parents’ opinions, understandable that the relationship should change.

Introduction

Following parental separation and divorce, grandparents in our study usually sympathised with their adult child and criticised the behaviour of their ex-son or ex-daughter-in-law. However, this was not the only strategy and, although it is recognised that divorce is a difficult process, some couples appeared to achieve reasonably harmonious arrangements and a minority of grandparents demonstrated that their non-partisan approach could also make a contribution to harmony. Most, however, did not think about the longer-term implications of their relationships with an ex-child-in-law. They were often angry and some were bitterly partisan in their feelings. Some grandparents took sides after the break-up and continued to harbour strong feelings of resentment for their sons or daughters-in-law long after their child’s marriage had ended. Parents often reported that their own parents had ceased contact with their exspouse because they held him or her responsible for the failure of the marriage. This was often presented as a natural feeling and one that might reasonably be expected of grandparents in a divorced family.

Grandparents’ partisan feelings

Twenty-five grandparenting couples and 11 lone grandparents in 30 different families were interviewed in the course of the research. There were 21 interviews with maternal grandparents and 15 with paternal grandparents. Five maternal and two paternal grandparents took an apparently neutral stance when asked about their relationship with their ex-child-in-law. They said that they were ‘civil’ and ‘polite’ to their child’s ex-spouse or explained that there was ‘no contact but no animosity’. In nine grandparent interviews (five with maternal and four with paternal grandparents) it was clear that they had retained friendly relationships with their divorced child’s ex-spouse. However, more than half of our grandparents (11 maternal and 9 paternal) expressed resentment.

Grandparents’ resentment

Choice of method

This research project took a qualitative approach. It emphasised the content of conversations and their hermeneutic analysis. This meant that the focus of attention was on the analysis of connected chunks of speech in the form of verbatim interview transcripts that were scrutinised for the presence of recurring themes and issues. Miles and Huberman (1994) have provided a list of what they see as the most important features of qualitative data. It includes features that influenced our decision to use qualitative methodology rather than postal questionnaires or interviews that might have sought answers to specific questions about grandparenting in divorced families. The most significant feature is what Miles and Huberman (1994, p 10) describe as “the inherent flexibility of qualitative data and their capacity to be varied as the study proceeds”. This was important because our study set out with few specific questions in mind. It was planned as a piece of exploratory research and aimed to apply a Grounded Theory approach (see Chapter One) by checking whether predictions generated within the data were confirmed when more interview transcripts were available for analysis. Qualitative data analysis presented itself as the most appropriate approach and the best method to achieve the study’s objectives (see Chapter One, p 4 of this book).

The families

The first group of parents that took part in the study was identified from divorce court records in six courts in South Wales and the West of England. Letters were sent to 162 parents who had divorced in 1997 and reminder letters were sent and telephone calls were made in an effort to boost the number that could be interviewed. Acceptances (see Table A1) were received from 36 parents in 34 different families and appointments were made to interview at least one parent in 29 different families. (Issues of cost, distance and a variety of other circumstances meant that some parents were not contacted.) All of these parents who had been granted a decree nisi in the first half of 1997 had participated in previous studies of divorce conducted by the university, but many had moved away and could not be contacted.

Grandparents and parental divorce

Research suggests that good quality contact between children in divorced families and their non-resident parent and grandparents is beneficial to their long-term adjustment (see Dunn and Deater-Deckard, 2001). There is a general conclusion that children’s continuing contact with both parents is likely to be helpful in enabling them to avoid adverse reactions to their parents’ divorce (Rodgers and Pryor, 1998). Marriage breakdown, however, can have negative effects on relationships between grandparents and grandchildren, and grandparents on the father’s side of the family may see their grandchildren less frequently or, in some circumstances, lose touch with them entirely.

In their study of 86 members of the Grandparents’ Federation in Britain, Drew and Smith (1999) asked whether grandparents, whose contact with their grandchildren had been lost as a result of divorce, were ‘innocent victims’ or ‘agents in cross-generational family dysfunction’. Their study hypothesised that grandparents who had been deprived of contact with their grandchildren also had disturbed relationships with other family members. This might suggest, for example, that their difficulties with their sons and daughters-in-law were simply a symptom of wider personality and communication problems that made it difficult for them to form satisfactory relationships with others. The authors were unable to say whether grandparents were victims of divorce or “agents of their own misfortune” (Drew and Smith, 1999, p 210), but added that the general tenor of their findings pointed to them being “victims”. However, grandparents who join a grandparent organisation are a special group in the sense that they are likely to have experienced conflict and to regard grandparenting as an important aspect of their lives. Our study, in contrast, investigated grandparenting that took place on a broad range of family circumstances and did not have a particular focus on families in conflict. Nevertheless, it did explore the feelings of a small number of grandparents who were deprived of contact and we comment (see Chapter Eleven) on their strategies for coping with the problem.

Cherlin and Furstenberg (1992), borrowing a phrase from Troll (1983), describe grandparents as the ‘family watchdogs’. These authors explain that the extended family comes into its own at times of crisis and not at times of ‘health and prosperity’.

Introduction

Our interviews sought to discover what happens when grandparents and grandchildren spend time together. Our focus in this chapter is on grandchildren who have regular face-to-face contact with grandparents and the importance they and their grandparents attach to the grandparent–grandchild relationship.

The grandparents’ perceptions

Grandparents who saw their grandchildren regularly reported that they went shopping, shared meals, accompanied grandchildren on family outings, went for walks and talked to them about school and their other activities. There were few differences between maternal and paternal grandparents in the activities they shared with their grandchildren; however, seven in ten maternal grandparents (but no paternal grandparents) reported that they helped grandchildren with schoolwork. Two thirds of the maternal grandparents, but only one third of the paternal grandparents felt that they ever talked seriously to their grandchildren. It may be that helping grandchildren with learning or engaging them in serious conversation (particularly about family matters or other sensitive issues) was ill-suited to the role that some grandparents played. Paternal grandparents were less likely than maternal grandparents to enjoy the sustained contact that made these activities possible. They may also have wanted to avoid the accusation of interference in their grandchild’s upbringing and preferred, therefore, to retain a light-hearted tone while their grandchildren were with them.

Half of the maternal grandparent group stated that they were involved in teaching or encouraging their grandchildren in hobbies, games and sports. Grandfathers reported that they were involved in outdoor sports, computing, country walks and active pursuits with their grandchildren, but grandmothers frequently restricted themselves to ‘traditionally female’ activities in the home. Although the paternal grandparents interviewed said that they did not help children with schoolwork, they were just as likely to report that they encouraged their grandchildren’s leisure activities.

The focus of grandparents’ attention

The evidence suggests that grandchildren, on their regular visits to their grandparents, were usually expected to amuse themselves by watching television or playing in the vicinity of their grandparents’ home while their grandparents talked to their adult child. As a result, it was quite common for children to have reservations about their visits to their grandparents. When Wendy (aged 12) was asked, “Does grandma talk to you a lot when you go there?”, she replied, “She’s always busy. She never sits down”.

Introduction

This chapter examines the range and extent of support that grandparents provided for parents and grandchildren, particularly after a marriage breakdown. We explore parents’ assumptions about grandparents’ support roles and consider the views of grandparents and their grandchildren about the help that they provided. In particular, we discuss how far grandparents were considered to be under an obligation to provide support, and how they responded to ‘a sense of duty’.

Grandparents were usually willing to support their adult children at moments of crisis. Most parents turned to their own parents for help in coping with the immediate effects of separation and divorce. Maternal grandparents were often anxious to do what they could to ameliorate the effects of the divorce. Consequently, they became more involved in childcare and saw their grandchildren more frequently.

Table 3 summarises the results of asking parents how often their children currently saw their grandparents, and how often they saw them when the couple was still married. In most cases, a parent reported their child’s contact with grandparents on both sides of the family. In 28 of the 44 families, only the mother was interviewed and in 11 families only the father was interviewed. There were five families in which both parents were interviewed. It was possible in these cases to use the evidence from two parents to confirm the accuracy of the totals provided. Information was obtained from 42 of the 44 families about maternal grandparents’ contact but the information about paternal grandparenting was less complete.

The frequencies reported have been converted to annual totals for ease of comparison. Table 3 demonstrates that there was not much difference between the frequency of contact of maternal and paternal grandparents before the divorce. However, as might be expected, there was an increase after the divorce in the numbers of paternal grandparents who rarely or never saw their grandchildren and a decline in the numbers who had very frequent contact. The evidence of this study is that maternal grandparents’ childcare duties were likely to increase after their daughter’s divorce and those who were in frequent contact before their daughter’s separation were likely to intensify their involvement. In contrast, paternal grandparents usually had to depend on their son for contact but some fathers did not have contact, and some of those who did were unwilling to take their children to their grandparents’ home.

This is a book about grandparents whose sons or daughters have divorced. It discusses the findings of a two-year interdisciplinary research study at Cardiff University. The project was supported by a grant from the Nuffield Foundation and the research was completed in May 2001. The project set out to explore family members’ perceptions of the impact of divorce on grandparenting. The study was designed to provide a tri-generational perspective and information was gathered from interviews with parents, children and maternal and paternal grandparents. In this chapter we aim to provide a description of the research and explain why we believe it is important to discover more about grandparents’ roles in divorced families.

Introduction

The breakdown of a marriage usually involves major readjustments for parents and children and a realignment of the network of contacts with friends and family. Mothers may need to make changes to the once familiar pattern of daily life and this often involves recruiting grandparents to provide support. Researchers have commented on the establishment of ‘matrilineal’ families, or what Aldous (1995, p 108) describes as “the female tilt in the kinship structure”. This refers to the marked tendency of mothers, children and maternal grandparents to form close alliances. Following a divorce, the mother normally becomes the resident parent (the parent responsible for the day-to-day care of the children), and the paternal grandparent connection is likely to break should fathers fail to maintain contact and keep the connection alive. Maternal grandparents who may have seen themselves as a latent resource during the marriage (see Riley and Riley, 1993) find themselves called into service when their daughter and son-in-law decide that they no longer want to live together. Bengtson (2001, p 5) concluded that “For many Americans, multigenerational bonds are becoming more important than nuclear family ties for well-being and support over the course of their lives”. The process of negotiating post-divorce parenthood is rarely easy because most parents are ill prepared for the changes (Smart and Neale, 1999). When help is needed, parents often turn to their own parents. Our project investigated the role that grandparents play in families and the effect of parental divorce on their relationships with grandchildren.

This chapter considers the issues of child discipline and favouritism and ‘the rules’ that apply to the relationship between grandparents and their grandchildren. It asks:

• • Does the ‘norm of non-interference’ mean that grandparents should hesitate to discipline their grandchildren?

• • Do grandparents often ‘spoil’ grandchildren, and do parents object to the grandparents’ indulgence and lax discipline?

• • Are there rules about reprimanding grandchildren when a parent is present?

• • Are grandparents who have been asked to provide regular childcare given free rein to discipline their grandchildren as if they were their own children?

• • Do parents feel resentful when they learn that their ex-spouse’s parents have reprimanded their child for bad behaviour?

Disciplining grandchildren

Parents, grandchildren and grandparents were asked to describe their experience and discuss their feelings about discipline and childcare. We anticipated that discipline might be a contentious subject but found that it was a source of conflict in few of the families that were interviewed. Some grandparents felt unsure about whether they should rebuke their grandchildren for bad behaviour, but few parents saw this as an issue. Only two of the 35 resident parents who were interviewed expressed strong reservations about their own parents’ disciplinary practices. For example, Eleanor’s mother, whose views are also discussed in Chapter Ten of this book, commented:

There were, however, other resident parents who had reservations about grandparents’ lack of discipline. Janet’s mother noted that her nine-year-old daughter and her younger brother were in the habit of seeking their grandparents’ permission for things that their mother had already refused to grant.

Ingrid’s mother also noted that her parents did not discipline her three children as much as she felt they should: