Ages and Stages: Parenting Time for a 20 month old

A recent decision by Shore, J., in Czyzewski v Fabro (2022 ONSC 4883) is a helpful guide for family mediators and arbitrators when helping parents determine the best interests of a very young child.

The case is about a father with relatively limited parenting time seeking a week-about parenting schedule. The father was unable to accommodate a different time-sharing arrangement because of his work schedule.

The court found that the 20-month old child had a strong and loving relationship with both parents, and that both were able to offer him a loving and stable home environment. Both parents appeared to respect the other and to understand the importance of the other parent’s role in the child’s life.

“This case comes down to the child’s age and stage of development, which includes the child’s need for stability”, wrote Justice Shore.

The court considered the mother’s reliance on case law where support and weight is given to the AFCC-O Parenting Guidelines. [1] Justice Shore notes that although she is not bound by the Guide, it contains helpful information in understanding a child’s developmental stage and schedules. For toddlers (18-38 months) “if parents have fully shared in the caretaking arrangements before the child has reached this age, and the child has an easy temperament, parenting time can be shared equally as long as the separations from each parent are not too long (no more than  two to three days or two nights for example.”

Justice Shore concludes that a week-about schedule for the child was not in his best interests. It was not in the best interest of a child this age to be away from either parent for a full week, even with an overnight with the other parent mid-way through as proposed by the father.

“In no way is this a reflection on the father’s ability to care for the child, but more a reflection on the child’s developmental needs at this time in his life.”

The court however significantly extended the child’s parenting time with his father during the weeks that the father was available to care for the child.

This helpful decision reinforces the relevance of the AFCC-O Parenting Plan Guide and Template for use by family mediators and arbitrators.

For more information contact our mediation-arbitration team:

Cliff Nelson:[email protected]
Borzou Tabrizi:[email protected]
Avagene Skervin[email protected]
Hilary Linton[email protected]


[1] Association of Family and Conciliation Courts Parenting Plan Guide, version 2.0.


About Hilary Linton

Hilary Linton is a Toronto family lawyer, mediator, arbitrator, parenting coordinator and trainer. After litigating civil and family matters for 14 years, she started Riverdale Mediation Ltd. which has become internationally recognized as a leader in family dispute resolution training. The Riverdale training team designs and delivers professional, affordable, relevant and inspiring workshops for family dispute resolution professionals. The services team offers family mediation, parenting coordination and mediation-arbitration services, using Zoom and, where appropriate, in-person at our Toronto offices. Hilary’s excellence has been recognized with Awards from the Family Dispute Resolution Institute of Ontario (2020), the Ontario Bar Association (2014) and with speaking and training engagements across Canada, the US, the Caribbean, Portugal, South Africa and Scandanavia.