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{{JP Boyd on Family Law TOC|expanded = violence}}{{JPBOFL Editor Badge
{{JP Boyd on Family Law TOC|expanded = violence}}{{JPBOFL Editor Badge
|CoAuthor = [[Kim Hawkins]], [[Vandana Sood]], [[Elizabeth Cameron]], and [[Rosanna Adams]]
|ChapterEditors = [[Fiona Beveridge]] and [[Samantha Simpson]]
|ChapterEditors = [[Fiona Beveridge]] and [[Samantha Simpson]]
}}
}}
==Civil claims for family violence==
==Civil claims for family violence==
The terms ''civil claims'' and ''tort claims'' are used interchangeably here. While most family law claims (e.g. claims for divorce, spousal support, division of property, etc.) are ''family law issues'' that are governed by legislation like the ''[[Divorce Act]]'' or the ''[[Family Law Act]]'', the right to sue someone for inflicting violence is its own claim in law. Claims for ''assault and battery'' are ''civil claims''/''tort claims'', and exist outside of the ''[[Family Law Act]]''.


Certainly, tort claims for abuse and violence can overlap with family law issues, but it helps to know that tort claims for abuse and violence arise independently from the ''[[Family Law Act]]'' and its treatment of ''family violence''. The ''Family Law Act'' has its own definition of ''family violence'' (including non-physical forms), emphasizes its impact on decisions around the care of children, and provides specific mechanisms like protection orders that are discussed in the section of on [[Family Violence and the Family Law Act]] in this chapter.
In British Columbia, "family law" typically refers to the law about divorce, spousal support, children's parenting arrangements, child support, and property division. If these issues are addressed in court, they are addressed through claims brought under the ''[[Divorce Act]]'' or the ''[[Family Law Act]]''.


==Introduction to tort law claims==
Family law is a kind of ''civil law''. "Civil law" refers to every kind of law other than criminal law. Other branches of the civil law include the law about contracts, the law about property, and the law about something called ''torts''. Tort law is the law that applies when someone does something, or doesn't do something, that causes harm to someone else. Tort law includes claims about a wide range of misbehaviour, such as negligence, defamation and invasion of privacy. Tort law also includes claims about things that are more directly relating to family violence, such as assault, battery, and infliction of emotional harm. Claims like these aren't covered by the ''Divorce Act'' or the ''Family Law Act''.  
The word ''tort'' comes from the Latin word for ''wrong'', and tort law deals with things like personal injuries, motor vehicle accidents, negligence, assault and battery, trespass, etc. The legal definition of a tort is ''a breach of a duty owed by someone to someone else which gives rise to a cause of action'', like a duty not to hit someone, a duty to drive carefully, or a duty not to dig a hole in your lawn that someone might fall into. Generally speaking, these sort of tort claims aren't spelled out in laws the way that the rules against robbery or assault are set out in the ''Criminal Code''. Tort claims are part of the ''common law'', the law that the courts (as opposed to the legislature) have created and maintained for hundreds of years.


If a claim for assault and battery is made in a family law claim, it will be treated by a judge as a ''tort law'' claim, and bring ''common law'' principles and rules into the case.
Tort claims for family violence can overlap with family law issues. They can be the subject of a lawsuit on their own, or they can be combined with a lawsuit brought under the ''Divorce Act'' or the ''Family Law Act''. While the ''Divorce Act'' or the ''Family Law Act'' do talk about family violence, in the context of children's parenting arrangements, protection orders and conduct orders, neither act provides financial compensation for the effects family violence. That is what tort claims are for.


Tort claims are not like criminal charges where the court can punish the wrong-doer with jail or a criminal record. The remedy for a victim of family violence is primarily ''restorative'' or ''compensatory''. They would ask for an award of ''damages'' to make good the harm the person suffered and its consequences. Damages are money payments and may be awarded for, among other things:
==Introduction to the law of torts==


*pain and suffering resulting from the violence, sometimes just called general damages,
The word "tort" comes from the Latin word for "wrong" or "injustice." ''Tort law'' is essentially a set of legal tools that developed to compensate people who have been harmed by someone else’s wrongful act or omission. A tort is a breach of a duty someone owes to someone else, such as a duty not to hit someone, a duty to drive carefully, or a duty not to dig a hole someone might fall into. However, not all actions that cause harm are torts. It's crucial to talk with a lawyer to see if harm done to you is a tort.
*loss of enjoyment of life as a result of the impact of the violence,
*past wages lost because of the violence,
*future wages lost because of some inability, illness or other impairment resulting from the violence (this is sometimes referred to as lost earning capacity),
*rehabilitation and job retraining <span class="noglossary">costs</span>, and
*past and future medical care expenses related to the injuries suffered from the violence.


Damages can also be claimed as ''punitive damages'' or ''aggravated damages''.
Most tort claims come from the ''common law'', which means they developed and evolved over the course of decades, and even centuries, as courts recognized new kinds of legal claims to address different problems in society. As a result, tort claims are not created by legislation the way that family law claims are based on legislation like the ''Family Law Act'', ''Divorce Act'' and the Child Support Guidelines. That said, some torts are "statutory torts" that are written into legislation. One example is claims for violation of privacy under the provincial ''Privacy Act'', which defines specifically what the tort of violation of privacy is.


Aggravated damages are awarded when the wrongful act took place in humiliating or undignified circumstances or when the wrongful act was particularly horrendous. By law, aggravated damages are to be combined with general damages. Punitive damages are not intended as compensation to the victim, but rather are awarded when the wrongful act deserves additional punishment because it was of a "harsh, vindictive, reprehensible and malicious nature." They are an effort by the court to deter others from committing similar acts.
===Damages===


The most common tort claim in situations of family violence is a claim based on ''assault and battery''. ''Assault'' technically means wrongfully threatening to harm someone. ''Battery'' means wrongfully attacking and harming someone. Assault and battery can include sexual assault, and a spouse can make a tort claim against their former spouse for sexual assault.
When a tort claim is proven, the result will be an order for the payment of financial compensation, or ''damages'', to the victim. The precise dollar value of these damages is based on the concept that every injury or harm, and every consequence suffered by the victim, has a dollar value. Some damages are easier for a court to calculate if it has evidence of direct financial loss to the victim, like lost wages or the cost of medical expenses. These direct financial losses are called ''pecuniary damages''. Other damages, such as pain and suffering, are more difficult to measure because they are more subjective. Damages for pain and suffering are called ''general damages'', or ''non-pecuniary damages'', and the courts tend to look to past cases with similar facts in order to calculate a dollar value.  


==Starting a civil claim==
General damages can be awarded for:
A tort claim must be made by the person who has suffered the family violence. In family law proceedings, tort claims are usually included with the ''other'' relief asked for in the [[Form F3 Notice of Family Claim]] or [[Form F5 Counterclaim]]. Although a tort claim can be made on its own, without claims for things like divorce, parenting arrangements, and so forth, if you want to make a claim in tort as well as other family law claims, it is very important to include all your claims in one proceeding because otherwise you might not be permitted to bring the tort claim separately at a later date.


Tort claims can only be heard by the Supreme Court. The Provincial Court does not have the jurisdiction to deal with tort claims.
* pain and suffering from the family violence,
* emotional trauma,
* impairment to family or social relationships, and
* loss of life enjoyment due to the lasting impacts of the violence.


==The challenges of tort claims==
Pecuniary damages can be calculated for:


This discussion is not meant to discourage persons who have suffered family violence from making tort claims for damages resulting from family violence. It is only meant to bring to readers' attentions the difficulties that can sometimes accompany tort claims relating to family violence. Notwithstanding these difficulties, it can be empowering and liberating for a victimized spouse to hold an abusive spouse accountable for family violence and see justice done. If you have been sexually and/or physically assaulted, you should talk to a lawyer who is experienced in handling such claims and seek advice.
* past wages lost due to the family violence,
* future wages lost from an inability, illness, or other impairment from the violence (sometimes referred to as lost earning capacity),
* rehabilitation and job retraining costs, and
* past and future medical care expenses tied to injuries caused by the violence.


The first drawback of a tort claim is that you will, in all likelihood, have to hire a lawyer if you want to make a claim in tort against your spouse.  The law governing tort claims is not set out in a statute, like the ''[[Family Law Act]]'' or the ''[http://canlii.ca/t/8487 Negligence Act]'', it's mostly based on the common law. In order to succeed in your claim, you will have to prove that the assault or sexual assault took place, and that injuries resulted. It is often quite complicated to prove injuries, especially where they are mainly psychological or emotional.
General and pecuniary damages are both forms of ''compensatory damages'', as they are awarded to compensate the victim for their harm and losses.  


Lawyers, of course, are expensive. While you may get some of your legal costs awarded to you if you're successful, that only happens at the end of the day after you've already paid a few months' or a few years' worth of bills. Lawyers who practise family law do not work on a contingency basis where they get paid out of the client's award. They charge by the hour.
''Aggravated damages'' are awarded by a judge where the circumstances of the harm are especially humiliating or undignified. The court may separately identify aggravated damage amounts, or award them as part of general damages. The purpose of aggravated damages is to compensate the victim when the circumstances of the harm are humiliating, oppressive, or malicious. In the context of family violence, the circumstances of the harm often qualify for aggravated damages. The unique power dynamics in many intimate relationships, the fact that there is often a significant size and strength difference between the parties, and the wide-ranging negative consequences that arise when family violence is part of someone's daily life, increase the likelihood that aggravated damages will be awarded.  


Secondly, even if you're successful, your spouse must have some money or other assets from which they can pay your damages if you win. It's no good to spend tens of thousands of dollars on legal fees and win only to find that your spouse has no way to pay your award. This is called a ''dry judgment''.
''Punitive damages'' are another form of damages. They are different from other kinds of damages and punitive damages are not about compensating the victim, they're about:


Note, however, that courts have factored damages for assault and battery into the calculation of who gets what when it comes to division of assets. In ''[http://canlii.ca/t/1f56v Megeval v. Megeval]'', 1997 CanLII 3721 (BCSC), a tort claim was made in the same proceeding as a division of property claim. The court divided the family property equally between the parties, but awarded Mrs. Megeval $139,150 in damages for injuries resulting from assault. This amount was paid from Mr. Megeval’s share of the family property.
* punishing the defendant, and
* send a strong message to the defendant and to other people, to discourage them from doing similar things.


A third drawback to making a tort claim is you will have to testify about the family violence and the effect it had on you in a very open, honest and personal manner. You will have to disclose your medical and counselling records, if there are any. You may also have to submit to medical and psychological examinations, both to prove your claim and sometimes by an independent expert appointed by your ex-partner.
Punitive damages are only awarded if the combined effect awards for general and aggravated damages is insufficient to achieve the goals of punishment and deterrence.


==Limitation periods==
===Specific tort claims===
 
Canadian law students learn about tort law in their first year of study. It's a major part of the Canadian legal system and can be thought of as a set of legal tools judges have developed to address wrongdoing and compensate people who have suffered harm. Tort claims are divided into distinct torts, each with its own requirements. The most frequent tort claims in family violence cases are the torts of ''assault'', ''battery'', and ''intentional infliction of emotional distress''. In tort law, "assault" means wrongfully threatening someone, and "battery" means wrongfully applying force without the victim's consent. The tort of ''intentional infliction of mental distress'' holds someone legally responsible when their outrageous, deliberate behavior causes another person serious, provable mental harm. Assault and battery can include sexual assault.
 
Other possible torts in family violence cases include ''public disclosure of private fact'', and ''false imprisonment''. Note that tort law uses specialized language, so your understanding of what "mental distress" is might differ from how tort law defines it.
 
Torts are always developing, although changes tend to be gradual and in response to broader changes within society as a whole. As family violence, and society's concerns about it, has gained more attention, the Canadian courts have been asked to consider expanding tort law to address the harms of family violence in new ways. In 2022, the Ontario Superior Court recognized a new, stand-alone ''tort of family violence'' in the trial decision of ''[https://canlii.ca/t/jmpnf Ahluwalia v. Ahluwalia]'', 2022 ONSC 1303. The Ontario Court of Appeal overturned that finding in ''[https://canlii.ca/t/jz277 Ahluwalia v. Ahluwalia]'', 2023 ONCA 476, concluding that existing torts (like battery, assault, and intentional infliction of emotional distress) are sufficient to address the problems of family violence. In February 2025, the Supreme Court of Canada heard arguments to determine if such a new tort should be recognized across Canada. A decision is expected in 2025, and it could influence the way courts handle family violence claims in the future. It is important to seek legal advice before relying on any specific tort, as the law in this area may change significantly depending on the Supreme Court of Canada's ruling.
 
===Starting a civil claim===
 
A tort claim is a ''civil claim'' and must be made by the person who has suffered the harm. A tort claim about an incident or series of events that happened within a domestic relationship can be made alongside a family law claim in a family law proceeding, or as a stand-alone tort claim in a general civil proceeding.
 
To include a tort claim in a family law proceeding, you must start your case in the Supreme Court of British Columbia by filing a Notice of Family Claim. The family court division of the Provincial Court cannot hear tort claims, so any family violence–related tort claims need to be added to a Supreme Court case.
 
If you wish to bring a tort claim on its own, you will likely file a Notice of Civil Claim in Supreme Court. Although certain tort claims can be brought in the Provincial Court’s small claims division, that court’s monetary jurisdiction is limited to $35,000. The Civil Resolution Tribunal can also hear some small claims matters, but it is limited to awards of $5,000 or less.
 
Because different courts or tribunals have different rules, procedures, and monetary limits, it's wise to get legal advice to figure out which court is most appropriate for your tort claim.
 
Another consideration when starting a tort claim is ''timing''. It is crucial that you bring the claim within the proper limitation period. (We'll talk about limitation periods a bit later.) If you do not file your claim in time, you will miss your opportunity to bring your claim at all. Again, it is important to speak to a lawyer to understand the limitation period that applies to your case.
 
===The challenges of tort claims===
 
This discussion is not meant to discourage individuals who have suffered family violence from making tort claims. It is meant to raise some of the difficulties that can accompany tort claims relating to family violence. Despite these challenges, it can be empowering to hold an abusive person accountable for their behaviour. If you have been sexually or physically assaulted, you should talk to a lawyer experienced in handling such claims and seek advice to determine whether your case is likely to succeed.
 
====Costs====
 
The first drawback of tort claims is that they are often expensive to bring to trial. You will likely need to hire a lawyer if you want to make a tort claim against your spouse. The law governing tort claims is rarely set out in a statute like the ''[[Family Law Act]]''. Instead, it is mostly based on the common law, also known as the ''case law''.
 
To succeed in your claim, you will have to prove that the tort occurred, the nature and extent of your injuries, and that your injuries resulted from the wrongful act. Proving injuries, especially when they are mainly psychological or emotional, can be complicated. You may even need to hire experts to assign a financial value to your injuries. For instance, if you are claiming the costs of future medical care, you will likely need a medical expert to tell the court about the type of treatment you will require and for how long.
 
====Recoverability====
 
Even if you're successful, your spouse must have some assets from which they can pay the damages you are awarded. It likely doesn't make sense to spend tens of thousands of dollars on legal fees and win, only to discover that your spouse cannot pay your award. This is called a ''dry judgment''.


A ''limitation period'' is a deadline by which a claim must be made and an action started. If there is an applicable limitation period, once it is expired you cannot make the claim. For assaults involving people whose relationship is not personal or one of dependency, the limitation period is generally two years after the incident.
One potential benefit of bringing your tort claim with your family law claim is that courts have generally factored damages for assault and battery into the division of property. This can make recovering your damages award much easier. In ''[https://canlii.ca/t/1f0tm Megeval v. Megeval]'', 1997 CanLII 3721 (BCSC), a tort claim was made in the same proceeding as a claim for the division of property. The court divided the family property equally between the parties but awarded the wife $139,150 in damages for injuries resulting from battery. This amount was paid from the husband's share of the family property.


There is not likely any limitation period that applies to violence between spouses or parents and children.
====Personal impact====


Under (s. 3 (1)) of the provincial ''[http://canlii.ca/t/8qx3 Limitation Act]'' there is no limitation period to claims based on sexual misconduct.
You will need to testify about the family violence and its effect on you openly, honestly and personally. The opposing party or their lawyer will question you about the tort and its impact on you in open court. Before a trial, you will also need to disclose your medical and counselling records, if any, to the opposing party and their lawyer, and participate in a discovery process that requires sharing relevant information. You might also have to undergo medical and psychological evaluations. These are standard parts of the civil law process, but many individuals find them exceptionally invasive.


Similarly, there is no limitation period on claims relating to non-sexual assault if the claimant was a minor or living in a personal or dependency relationship (s. 3 (i) (k)).  
==Limitation periods==
A limitation period is a deadline by which a claim must be made and a court action started. If a limitation period applies to a claim, and that period has expired, you cannot make that claim anymore. For many torts, including assaults involving people who are strangers, the limitation period is generally two years after the incident. Where assault involves people in an intimate relationship, or where the victim was in a relationship of dependency with the attacker, there is no limitation period. There is also no limitation period for claims relating to sexual assault, regardless of the relationship between the attacker and the victim.
 
Under section 3(1) of the provincial ''[https://canlii.ca/t/8qx3 Limitation Act]'', there is no limitation period for:
 
* claims relating to sexual assault,
* claims relating to assault, battery or misconduct of a sexual nature while the claimant was a minor, or
* claims relating to assault or battery while the claimant was an adult living in an intimate and personal relationship (or had a relationship of financial, emotional, physical, or other dependency) with a person who performed, contributed to, consented to, or acquiesced in the assault or battery.


==Awards==
==Awards==
The amount of damages a court may award for tort claims depends on the circumstances. If you can, get legal advice to help decide whether a claim is worthwhile in your particular circumstances. Outcomes vary widely, and many factors go into a judge's assessment of the appropriate award. Here are some examples of awards that the courts have made for tort claims in a family context:


The amount of the damages that a court may award for tort claims based on family violence always depends on the circumstances. It is important to get legal advice to decide whether or not making such a claim is economically worthwhile in your particular circumstances. The range of outcomes is very wide and many factors go into a judge’s assessment of the appropriate award but here are some awards that the courts have made for assault and battery in a family context:
* In ''[https://canlii.ca/t/jl5wr Schuetze v. Pyper]'', 2021 BCSC 2209, the wife was awarded a total of $795,000 following a violent incident for which the husband faced criminal charges. The majority of damages were for past and future diminished earning capacity, but $100,000 were general damages for pain and suffering. The wife's tort claim of ''battery'' was made in a separate civil action, not a family law proceeding, and she had expert evidence to prove her physical and psychological injuries.
 
* In ''[https://canlii.ca/t/j3tr8 Olds College v. Huxley]'', 2019 BCSC 2111, the plaintiff received $2,500 in general damages $2,500 in aggravated damages, and $5,000 for punitive damages in a defamation case against his former wife. She made serious and defamatory statements by email, Facebook, and YouTube and tried to reach as many people as possible.
* In ''[http://canlii.ca/t/g2h5c A.M. v. S.O.], 2014 BCSC 4 physical assault in the form of an open-handed blow to the head resulted in $20,000 for general damages.
* In ''[https://canlii.ca/t/gr5ld T.K.L. v. T.M.P.]'', 2016 BCSC 789, the step-daughter was awarded a total of $93,850 for breach of privacy and breach of fiduciary duty following her step-father spying on and video recording her in the shower. $85,000 was awarded for general damages, which included a $25,000 aggravated damages component. This case features the tort of breach of privacy under the ''Privacy Act''.
* In ''[http://canlii.ca/t/fsxwh Bird v. Kohl]'', 2012 BCSC 1424 the serious shoulder fracture, concussion, lacerations and scarring that resulted from repeated strikes with a shovel handle amounted to $75,000 for general damages, $15,000 for aggravated damages, $40,000 for lost wages and $25,000 for lost earning capacity.
* In [https://canlii.ca/t/g2h5c ''A.M. v. S.O.''], 2014 BCSC 4, physical assault in the form of an open-handed blow to the head resulted in $20,000 for general damages.
* In ''[http://canlii.ca/t/fwktw Constantini v. Constantini,]'' 2013 ONSC 1626 verbal abuse during the relationship and pre-meditated break-in and aggressive assault post-separation did not produce permanent disability but it did result in post-traumatic stress disorder. $15,000 was awarded for general and aggravated damages.
* In ''[https://canlii.ca/t/fsxwh Bird v. Kohl]'', 2012 BCSC 1424, the serious shoulder fracture, concussion, lacerations, and scarring that resulted from repeated strikes with a shovel handle amounted to $75,000 for general damages, $15,000 for aggravated damages, $40,000 for lost wages, and $25,000 for lost earning capacity.
* In ''[http://canlii.ca/t/fs8l9 D.G. v. R.M.]'', 2012 SKQB 296 a single instance of “horrific” sexual assault including striking, kicking and biting. $35,000 was awarded for general damages.
* In ''[https://canlii.ca/t/fwktw Constantini v. Constantini,]'' 2013 ONSC 1626, verbal abuse during the relationship and pre-meditated break-in and aggressive assault post-separation did not produce permanent disability, but it did result in post-traumatic stress disorder. $15,000 was awarded for general and aggravated damages.
* In ''[http://canlii.ca/t/1k2jm Gould v. Sandau]'' 2005 BCCA 190, the trial judge awarded $2,500 for an assault that broke a hand.
* In ''[https://canlii.ca/t/fs8l9 D.G. v. R.M.]'', 2012 SKQB 296, the facts involved a single instance of “horrific” sexual assault including striking, kicking, and biting. $35,000 was awarded for general damages.
* In ''[http://canlii.ca/t/1f56v Megeval v. Megeval],'' 1997 CanLII 3721 (BCSC) assault causing permanent disability resulted in $45,000 for the injury, $66,000 for lost wages and retraining, $2,500 for medical care and $5,000 in punitive damages.
* In ''[https://canlii.ca/t/1k2jm Gould v. Sandau]'' 2005 BCCA 190, the trial judge awarded $2,500 for an assault that broke a hand.
* In ''N.C. v. W.R.B.'' [1999] O.J. No. 3633 (Ont. S.C.J.) multiple instances of sexual, physical verbal and emotional abuse that caused post-traumatic stress disorder was awarded $65,000 for general damages and $25,000 for aggravated damages.
* In ''[https://canlii.ca/t/1f56v Megeval v. Megeval],'' 1997 CanLII 3721 (BCSC), assault causing permanent disability resulted in $45,000 for general damages, $20,150 for past wage loss, $66,500 for future wage loss, $2,500 for future care, and $5,000 for punitive damages.
* In ''[http://canlii.ca/t/fps0x Shaw v. Brunelle]'', 2012 ONSC 590 a serious wrist fracture resulting from physical ejection from the home resulted in $65,000 for general and aggravated damages, $25,000 for lost earning capacity, and an unspecified amount for cost of future care.
* In ''N.C. v. W.R.B.'' [1999] O.J. No. 3633 (Ont. S.C.J.), multiple instances of sexual, physical, verbal, and emotional abuse that caused post-traumatic stress disorder resulted in an award of $65,000 for general damages and $25,000 for aggravated damages.
* In ''[https://canlii.ca/t/fps0x Shaw v. Brunelle]'', 2012 ONSC 590, a serious wrist fracture resulting from physical ejection from the home resulted in $65,000 for general and aggravated damages, $25,000 for lost earning capacity, and a figure for costs of future care (to be assessed by an actuary).


These cases have been included only to give you a general idea of how the courts have treated tort claims based on family violence in the past. You should not rely on these cases to fix a dollar amount to your claim – seek legal advice from a lawyer with experience in this area.
These cases have been included only to give you a general idea of how the courts have treated tort claims based on family violence in the past. Damage awards in family violence cases involving assault and battery have changed and appear to be increasing at a rate higher than inflation. You should not rely on these cases to fix a dollar amount to your claim — seek legal advice from a lawyer with experience in this area if possible.


==Resources and links==
==Resources and links==
===Legislation===
===Legislation===


* ''[http://canlii.ca/t/8qx3 Limitation Act]''
* ''[https://canlii.ca/t/8qx3 Limitation Act]''
* ''[https://canlii.ca/t/849p Privacy Act]''


{{REVIEWED | reviewer = [[Gayle Raphanel]] and [[Samantha Simpson]], August 8, 2017}}
{{REVIEWED | reviewer = [[Rise Women's Legal Centre|Kim Hawkins, Vandana Sood, Elizabeth Cameron, and Rosanna Adams]], 16 June 2023}}


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{{JP Boyd on Family Law Navbox|type=chapters}}
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