Canadian Law and Domestic Violence
This outburst was no surprise. In a pre-mediation screening questionnaire, the mother said the father had abused her. Although she wanted to try mediation, she was unsure whether she could participate on an equal basis with the father. As the mediation progressed, the mother willingly acquiesced to the father’s visitation demands in his presence. However, she said privately that she did not want him near her or their children, and that she had agreed to his demands only because she was afraid of him. The mediation ended in an impasse, with no reported mention of the father’s abusive history or the mother’s fear of further abuse based on her conduct at the mediation.
This case illustrates a situation in which earlier participants in the case should have noted the existence of domestic violence and exempted the case from mediation. “Participants” refers not to the parties, but to those participating in the family law process: lawyers representing the parties, the clerk of the court, the judge, and the family mediator.
Ultimately, the mediator in a family case must screen for domestic abuse to determine whether mediation is appropriate. However, this determination should not be the sole responsibility of the mediator. Long before the mediator sees the case, other participants should screen for such abuse by asking the parties about domestic violence. Because some parties may not be literate, screening should include a personal interview in addition to a written questionnaire. Preferably, someone other than the mediator will conduct the interview.
Unfortunately, this does not usually happen. No state requires screening for domestic violence and abuse before mediation begins. In fact, some states do not provide an exemption from mediation even when screening indicates that a significant history of abuse exists. As a result, courts may send cases to mediation despite domestic violence and abuse, either because participants are unaware of the violence and abuse, or because no mechanism for exemption exists.
This practice must change. Legislatures must require screening by participants at every level, and an exemption from mediation when participants find domestic abuse. Legislatures also must require that all participants, especially family mediators, be trained to recognize signs of domestic violence and abuse. Participants must know about domestic abuse, screen each case to identify abuse, and assume that any alleged abuse did actually occur. If mediation is inappropriate, they should offer alternatives to mediation.
In incorporating concerns about domestic abuse into mediation statutes, legislatures should provide guidance to the participants by defining the types of abuse that might compromise the process and, therefore, should be identified during the screening process. Screening procedures must be simple enough to ensure wide use and uniform application, with precautions for the parties’ safety. In order to screen effectively, participants must be trained to detect domestic abuse. To maximize the detection of abuse, screening must be performed at every level.
Commentators have stated that the “initial wave of unabashed enthusiasm for divorce mediation and alternative dispute resolution (ADR) in general has given way to sober reassessment.” Feminists and battered women’s advocates object to the use of mediation when there has been any domestic abuse and believe mediation may be harmful for women. However, abuse is not unusual in relationships. Some form of domestic abuse occurs in most divorces before the separation is final, and it may affect the capacity of either or both parties to mediate effectively. Domestic violence or abuse itself can never be mediated. Abusers must know that domestic abuse is criminal, with no potential for any conciliatory process. Once abuse is detected, participants must have a method for exempting a case from the mediation process. However, if the parties can reach agreement on equal terms and neither party controls the other, family mediation, including matters such as child custody, visitation, and support, may be appropriate even though some abuse has occurred in a relationship.
Part II of this Article provides an overview of the mediation process. Part III proposes that all legislatures mandating family mediation allow exemption from mediation when participant screeners determine that, because of the level of domestic abuse, mediation is inappropriate. Part IV argues that legislatures also must mandate that all participants screen for domestic violence. To implement the required screening, participants must receive training about domestic violence. Part V concludes by discussing the multi-tiered screening process and the roles of the various participants in screening for domestic abuse.
Court-sponsored mediation is prevalent today in the United States and in foreign countries, including Canada and England. In some states, only two percent of filed cases are resolved by adjudication. Many cases are sent to mediation, and approximately seventy percent settle at the mediation conference. Most of the remaining thirty percent settle before trial, often as the result of the process begun in mediation. For example, the number of reported mediated cases in Florida increased from , in to almost , in . This movement toward mediation reflects a relatively long-term trend in Florida’s judicial system.
In mediation, a neutral third person encourages and facilitates the resolution of disputes. The mediator has no coercive power or authority to decide on behalf of the parties, or even to require the parties to agree. Mediation is a process of conflict resolution that returns to the parties the responsibility for making decisions. The goals of mediation include: reducing the court’s docket, reducing the demand on judicial resources, accelerating the rate of case resolution, reducing the cost of resolving conflicts, increasing the litigants’ satisfaction with the court system, and improving relationships between disputing parties.
Mediation is especially helpful in family disputes because of the unique nature of family law. Family matters involve not only the law and facts, but also feelings. An increase in the number of divorces and of children born outside marriage has caused states to seek methods other than litigation to solve family disputes involving child visitation, as well as financial matters. Mediation is one such method.
Mediation is an attractive alternative in family disputes, because it empowers the parties to devise agreements that meet their specific needs. Unlike the adjudicatory process, the emphasis in mediation is placed on establishing a workable solution, rather than on determining who is right or wrong. Decisions are made by the parties, not delegated to a judge. Mediation of divorce disputes began because of increasing court costs, delay, and escalation of conflict caused by dissatisfaction with the traditional method of solving family matters through litigation. To address this dissatisfaction, lawyers and therapists offered to help their clients settle cases in a non-adversarial manner.
The mediation process helps reduce parties’ hostility and children’s trauma from the divorce process. This is particularly significant when the parties are parents and will remain in contact after the marital relationship ends. The process encourages the parties to work together, isolate the issues, and learn through cooperation. Mediation produces stable agreements that are more likely to inspire long-term compliance by the parties. In addition, even when the parties do not reach agreement during the mediation process, research indicates that family cases often settle prior to trial as a result of issues discussed in mediation.
Family mediation is available through public and private forums. Some states have enacted statutes providing either mandatory or discretionary mediation of family matters. Additionally, some state courts have instituted mediation by court policy without statutory guidelines. At least thirty-four states and the District of Columbia have some type of court-based mediation program for domestic relations cases. State programs are used to resolve custody, child support, and other financial issues, such as alimony and property distribution.
The widespread use and increased acceptance of mediation require a lawyer to advise the client about mediation. The Model Rules of Professional Conduct supports this proposition. Professors Robert H. Aronson and Donald T. Weckstein have addressed the issue of whether, generally, lawyers have a professional responsibility to inform their clients about mediation. They suggest that, because of the increasingly well-known advantages of mediation, clients may expect their lawyers to discuss mediation. Family-law practitioners may have an obligation to discuss mediation, just as litigators may have an obligation to discuss settlement options. Regarding the Model Rules of Professional Conduct, Aronson and Weckstein state:
Model Rule .(a) requires a lawyer to consult with a client as to the means by which the client’s objectives are to be pursued. The Comments add that “the lawyer . . . should defer to the client regarding such questions as the expense to be incurred and concern for third persons who might be adversely affected.” Certainly exploration of use of Alternative Dispute Resolution procedures as a means of pursuing client objectives impacts on the expense to be incurred and may incorporate concern for third parties, for example, children in a marital dissolution matter . . . .
In advising a client, a lawyer is not limited to strictly legal concerns. See RPC . , Comment: “Advice couched in narrowly legal terms may be of little value to a client, especially where practical considerations such as cost or effects on other people, are predominant.” Consultation regarding ADR options can effectuate this broader advisory role of the lawyer.
Some experienced family lawyers and mediators conclude that a lawyer has an ethical duty to inform a domestic relations client about the option of mediation, and that failing to do so could result in findings of malpractice. More than law firms in the United States have agreed to a statement promising to encourage the use of alternative dispute resolution by their clients. These firms promise that “the responsible attorney will discuss with the client the availability of ADR procedures so the client can make an informed choice concerning resolution of the dispute.” Likewise, Canada requires lawyers to include with an original petition a statement attesting to efforts for settlement and dispute resolution. Even where such information is not required, the family-law practitioner should inform clients of the availability of family mediation.
Traditionally, mediation has been a voluntary process. Recently, some jurisdictions have adopted mandatory mediation, requiring the parties to mediate. Given the concept of self-determination inherent in mediation, mandatory mediation appears to be a contradiction in terms. However, these statutes merely mandate the mediation process, not an agreement by the parties. In , California became the first state to require mandatory mediation. Now, many jurisdictions have similar statutes. Regardless of whether a statute requires mediation or authorizes mediation, once a court orders participation in the mediation process, the parties must mediate unless a statute provides for exemption.
Not all states mandating mediation provide an exemption from mediation in the face of domestic violence. However, exemption from family mediation is necessary because spousal abuse is pervasive in our society. Abuse is estimated to occur in thirty percent of marriages. Most victims of abuse are women; only five percent of reported spouse abuse victims are men. Mediation in domestic relations cases raises concerns about safety, because studies find more abuse after mediation sessions than after trials. Mediation also may be unsuccessful because of an imbalance of power between the parties, as well as a limited capacity of the parties to advocate effectively for themselves.
Some state legislatures have responded to the need to exclude abused parties from mediation. New Mexico enacted the first exemption statute, and many states followed. Recently, California amended its statute to provide an exemption for domestic violence.
Critics of mediation observe that mediation is desirable only when the parties’ bargaining power is relatively equal. Recognizing this fact, some states have provided exemptions when mediation is “inappropriate under the facts of the case,” or when a party can show good cause against mediation. In various exemption provisions, state legislatures mandate subjective judgments by the participants. When participants have the power to decide whether abuse has reached a level that would compromise the process, or meets a required “good cause” standard, they have the flexibility and discretion to determine the appropriateness of mediation. All participants, including lawyers, clerks, judges, and mediators, must have the ability to make that determination.
Legislatures in two states have included caveats that should be considered by all states mandating mediation. New Hampshire provides an exemption unless the alleged victim requests mediation. New Mexico requires the court to halt mediation if there is evidence of domestic violence unless: ) the mediator has substantial training concerning the effects of abuse; ) the party is capable of negotiating without an imbalance of power; and ) the mediation process contains appropriate provisions to protect against an imbalance of power.
In providing statutory exemptions from family mediation, legislators must establish detailed guidelines. These guidelines should address participants’ discretion in implementing exemptions, as well as methods of implementing screening safeguards. Unfortunately, no bright-line test distinguishes cases where limited abuse does not preclude effective mediation from cases where power imbalances make mediation inappropriate. All participants are responsible for making these difficult determinations. Therefore, implementation of multi-tiered screening procedures for domestic abuse is necessary.
Legislators are likely to encounter difficulty during the process of defining domestic violence and abuse for the purpose of exempting parties from mediation. Ideally, legislators will define domestic violence along variables indicating severity. The variables should be incorporated into screening tools identifying the violence and rating its severity.
Some authorities recommend expanding the definition of domestic violence beyond physical assault to include economic, emotional, and sexual assault. Florida defines domestic violence as “any assault, battery, sexual assault, sexual battery, or any criminal offense resulting in physical injury or death of one family or household member by another who is or was residing in the same single dwelling unit.” In screening for domestic violence, however, the broader term “domestic abuse” better defines acts of intimidation, harassment, coercion, and violence perpetrated by an abuser against a current or former intimate partner.
Identifying cases to exempt and cases to mediate is difficult. When there has been a “culture of battering,” an exemption for spouse-abuse cases is necessary. When the abuse has been less severe, involving only isolated acts of abuse that did not allow one party to control the other, often the parties can safely and fairly mediate.
In relationships with a culture of battering, three elements are present: first, there is always some abuse, either physical, emotional, sexual, or economic; second, there is a systematic pattern of domination and control by the batterer; third, and finally, the victim hides, denies, and minimizes the abuse. Once the parameters of abuse are defined, a participant must determine whether the abuse has affected a relationship to the extent that mediation is inappropriate. In order to make such a determination, each participant screens both parties. The screener asks questions about the many levels and forms of abuse, including physical, sexual, economic, and emotional.
Discerning the parties’ degree of risk and need for safety may be a hard task. Fearing threats or injury, a battered party may have difficulty responding to screening questions, thereby hiding signs of domestic violence. Secrecy and distortions shroud the complex dynamics of domestic violence. Therefore, a screener should not minimize any disclosure, even an isolated incident, of abusive behavior.
Screeners need an understanding of a party’s exposure to violence and abuse, the strategies used for protection of the victim, and the ways violence affects a party psychologically, physically, economically, and socially. The screener should understand that domestic abuse is a “pattern of interaction that inevitably changes the dynamics of the intimate relationship within which it occurs.” This abuse is not simply a pattern of episodes occurring over time or a list of aggressive behaviors calculated to see who won a fight. Often both parties understand the meaning of specific actions and words within the context of their relationship. A simple statement, such as “remember last Thanksgiving,” can serve as a control mechanism, acting as a reminder of past battering and a warning to beware. Abused parties must comply or suffer the consequences.
Before each proposed mediation, screeners must distinguish between a relationship where the parties still are able to mediate on equal terms, despite prior episodes of abuse, and a relationship experiencing a culture of battering, in which mediation on equal terms is impossible. Even a trained mediator is likely to find this task difficult.
During its first year, the Alachua County Mandatory Family Mediation Program in Florida received written responses to a pre-mediation screening questionnaire from seventy-eight women and seventy-four men. Asked whether there was physical abuse in their relationship, thirty-seven women and twenty-two men answered “yes.” When asked about mental or emotional abuse, fifty-six women and thirty-seven men “yes.” Twenty-one women and sixteen men also reported alcohol or drug abuse during their relationships.
If either party fears the other, mediation on equal grounds is unlikely. When asked if they currently felt afraid for any reason, twenty women and eleven men stated “yes.” However, when asked if they were currently afraid of physical harm, six women and four men answered “yes.” Twenty-four women and sixteen men indicated they feared their partners’ ways of expressing anger. Results of these limited screening questionnaires suggest that abuse is more common in relationships than the national statistics indicate. The survey also asked questions to determine whether parties communicated despite abuse. The first screening survey asked general questions regarding communication. When asked whether they were less able to communicate on an equal basis because of the anger level or abuse, twenty-nine women and twenty-three men answered “yes.” When asked if they had an “equal say” in their relationship, sixteen women and twenty-three men indicated they did.
Although the initial survey did not specifically ask about communication during mediation, a revised survey asked specific mediation questions, for example: “Do you believe you would be able to communicate with your spouse on an equal basis in mediation sessions?” Thirty women and thirty-one men responded to the revised survey. Of these, fourteen women and twenty-six men said “yes.” Asked whether they were concerned about mediating in the same room as their partner, three women and two men said they were.
Although abuse is prevalent (in only three cases did both parties indicate no abuse), few respondents indicated that they felt unable to mediate. In private pre-mediation interviews, following the screening questionnaires, every respondent indicated a desire to try mediation. This response was surprising, given the expectation that some parties would say they did not want to mediate.
Possibly, the mediator’s presence during pre-mediation interviews influences the parties. Other circumstances that may make parties feel compelled to mediate include: notice of the procedure, presence of the parties at the designated place for mediation, and presence of their lawyers. Therefore, if a mediator screens, the mediator should be just one component in the overall screening process.
Screening instruments are aids to assessment and should not replace high levels of investigative interviewing and assessment. However, simply asking whether a party has abused, or has been abused, is not likely to elicit an accurate response. Screening tools administered in a perfunctory manner may fail to uncover abuse. Furthermore, the abused person may describe serious verbal, psychological, or other abuse, and merely see it as a part of daily life.
Therefore, screening should be multi-tiered, conducted by all participants. At some point, a neutral person trained in recognizing symptoms of domestic abuse should interview both parties.
If pre-mediation screening does not occur, mediation should not be required. All participants in this multi-tiered screening process require training in domestic abuse and the power imbalance created by such abuse. Each participant should receive information regarding domestic abuse, address those concerns, and then make a decision regarding whether mediation is appropriate.
Participants must screen for both past and present abuse. The type of screening mechanism varies, depending on which of the participants uses the tool. Screening devices include questionnaires and interviews. These may be written, by telephone, or in person. They must remain confidential to ensure the safety of the parties. The role of each participant differs slightly; therefore, each is discussed seriatim below.
The first discussion regarding mediation of family matters occurs when a client meets with a lawyer. After informing the client of the mediation option, the lawyer helps the client determine whether mediation is appropriate. In the multi-tiered screening process, a lawyer is in the best position initially to identify and deal with a client’s circumstances. To determine whether the client participated in domestic abuse, either as victim or perpetrator, the lawyer may screen by use of a questionnaire or a personal interview.
The lawyer or client may believe that the lawyer’s presence during a family mediation session will help to equalize the process. The lawyer and client should decide whether the lawyer will be present during mediation sessions.
Requirements vary among the states regarding an advocate’s presence in mediation sessions. For example, Alaska provides for the presence of counsel in divorce mediation, but does not provide for the presence of counsel during custody mediation.
State bar associations should offer training on domestic violence to help family lawyers advise their clients regarding family mediation. Lawyers may be simply unaware of past domestic abuse that makes some cases inappropriate for mediation. In such a case, the presence of an uninformed lawyer at a mediation session provides insufficient client protection.
Once a client and lawyer decide whether to use mediation, the lawyer should state in the initial pleading whether mediation is appropriate. The lawyer should have an opportunity to petition the court to exempt any required mediation, if the lawyer believes the parties are not equal in their bargaining positions. Finally, statutes must mandate a lawyer’s presence at mediation when needed for the parties to bargain equally. If lawyers are not present during mediation, states should provide that no agreement will become final until it has been lawyer-approved.
Because the clerk of the court is the first person to take the family matter into the court system, the clerk should have a protocol for determining whether mediation is appropriate. If a lawyer recommends mediation, the clerk should institute a screening procedure. Ideally, this procedure will include interviews with the parties. A lawyer may be unaware of the problems of domestic abuse or too biased to discern potential problems with mediation. Thus, a neutral Clerk should make an independent finding as to whether mediation is appropriate.
The clerk should employ trained deputies, lawyers, or psychologists to interview the parties in each case filed with the family court. The initial interview may be by telephone, written questionnaire, or in person. If a telephone interview or questionnaire reveals a reason for concern, a follow-up personal interview should occur.
Many parties enter the courthouse unrepresented. In pro se cases, the parties may not have the knowledge or skill to make accurate representations regarding mediation. In these instances, the clerk’s interview will be the first opportunity to assess the merits of mediation. After the screening interview, the clerk should make a recommendation regarding mediation, refer the family matter to the proper division of the court and, when necessary, recommend the use of a guardian ad litem or other court services.
In many states, judges manage their own cases and possess broad discretion to order family mediation. In a multi-tiered screening process, a judge receives a case with the lawyers’ and clerk’s recommendations regarding mediation. After questioning the parties, the judge determines whether mediation is appropriate. Alternatively, the judge may develop a separate screening process. Some judges may rely on the representations of the lawyers or the recommendations of the clerk. A judge makes a specific finding on the appropriateness of mediation in an order requiring family mediation.
In order to make a determination about family mediation, judges need additional training in substantive family law, mediation techniques, and domestic violence. To help judges learn to screen for the unique problems of domestic violence, some states require training programs. Legislatures should require such training to help sensitize judges to the psychology of the battering relationship, and enable judges to determine whether mediation is appropriate.
In a multi-tiered screening process, a participant other than the mediator completes a screening. This participant can be a lawyer, clerk of the court, or the judge. If any of these participants recommends that mediation should not occur, the case should be exempt from mediation. However, if a multi-tiered process is not used, the mediator needs a designee, usually another mediator or colleague, to screen for domestic abuse. This reduces the likelihood of mediator bias toward one of the parties during the mediation. The alternate mediator or designee may use a questionnaire or separately interview each party. The person completing the screening determines whether mediation should occur.
Regardless of representations by parties or their lawyers, the mediator ultimately determines the fairness of the mediation process. Once the mediator or designee decides that mediation is appropriate, the mediator should employ safety measures to protect the participants during mediation. Such measures may include mediating in the presence of the parties’ lawyers or mediating with parties in separate rooms. If the mediator determines that the mediation is progressing inappropriately, the mediator should declare an impasse. For instance, a mediator in Kansas may terminate a session based on the belief that continuation would “harm” one or more of the parties.
Family mediators may possess a variety of professional credentials, including legal training, mental-health training, or accounting certification. No universal standards for family mediators and mediation trainers exist. Many jurisdictions maintain a list of mediators who have completed certification training. In the absence of uniform standards, states must train family mediators about domestic abuse, including a component on domestic violence, to enable mediators to handle abuse cases. Presently, no state requires training in domestic abuse as part of its mandated mediation certification program.
Many family matters can be successfully mediated if abuse has not created an unequal balance of power. The key is to distinguish chronic abuse cases, always inappropriate for mediation, from cases of limited abuse, where the parties can bargain equally. Unfortunately, no bright-line test exists. However, screening by each participant in the process helps exempt inappropriate cases from mediation.
Legislatures must amend existing mediation statutes to require screening by participants at every level and exemptions from mediation when participants discover evidence of domestic abuse. Legislatures also must require that all participants receive training in order to recognize signs of domestic violence and abuse.
Lawyers, in their initial pleadings and responses, must note evidence of domestic abuse and indicate whether mediation is appropriate. When family matters come before a clerk of the court, the clerk should be required to determine whether domestic abuse has occurred and, thus, whether family mediation should occur. In deciding whether to send cases to mediation, judges must make findings regarding domestic abuse and whether mediation is likely to succeed. Finally, family mediators or their designees must screen all cases for domestic abuse.
Ultimately, if any participant in the multi-tiered screening process determines that mediation is inappropriate, a mediation exemption must be available. A successful mediation requires equal power between the parties, and a battered person does not have equal power.
Amicable divorce is the exception, not the rule. In a perfect world, spouses who intend to divorce would sit down together in an attempt to deal with the consequences of their separation and divorce in a fair and practical manner. All too often, however, separated and divorcing spouses cannot even talk to each other in a civilized manner. So, how can we expect them to communicate in a rational and constructive way for the purpose of resolving the problems generated by their divorce? Of course, if they have no assets and no children and neither is financially dependent upon the other, there is really very little to talk about. They can get a low cost uncontested divorce and deal with any emotional trauma as they see fit.
In most cases, divorce is not quite that simple. There will be children who still need the love of both parents. There may be substantial assets to divide, including spousal pensions. There may also be an entitlement to spousal and child support. So how should divorcing spouses deal with these issues? Even sophisticated people need professional help. Prospective divorcees may need advice from a variety of professionals, including family and individual therapists, accountants, actuaries, business valuators, and lawyers.
In the typical divorce scenario where substantial assets are involved, each spouse should consult a separate lawyer – hopefully, both lawyers will be specialists in family law. The lawyers take instructions from their respective clients and will then attempt to negotiate a settlement of all disputed matters. All this takes time and money – even in those cases where there is no recourse to litigation.
But lawyers cannot always reach a settlement on behalf of their clients. In a small number of cases, a full blown trial may materialize unless other options are examined. What are these other options? There are as many options as the parties and their lawyers can devise. Be creative! Three options of particular significance are (i) mediation; (ii) neutral evaluation; and (iii) arbitration.
Before engaging in protracted acrimonious litigation, divorcing spouses should speak to their lawyers about these and other alternative processes. They might also want to spend some time or money at their local public or university library or bookstore to see if they can find relevant information about so-called A.D.R. processes.
The opportunities to be personally creative in seeking constructive solutions to the parenting and economic crises of separation and divorce are legion. Check them out and do your homework. There is a better way than battling in the courts. What you need are the inclination and industry to evaluate your options – both in terms of process and substantive dispositions.
Works Cited
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Bowman, supra note , at . See Milne, supra note , at (stating that improved relationships were noted for almost one-third of the parties in one study).
CAL. CIV. CODE Ã?§ (West ), later repealed and added, without substantive change, to CAL. FAM. CODE Ã?§Ã?§ – (West ).
Carol A. Caldwell, Mediation in Cases of Domestic Violence in Florida’s Eighth Judicial Circuit n. (Spring ) (unpublished manuscript, on file with the author) (citing Letter from Linda Harvey, Family Mediation Director, Mediation Center of Kentucky, to Carol A. Caldwell, student, University of Florida College of Law, Mar. , )
Clare Dyer, Quick, No-Fault Divorce Plan, MANCHESTER GUARDIAN WKLY., Dec. , , at . The Lord Chancellor of London introduced no-fault divorces, available on demand after a -month wait. Id. Where divorces appeared inevitable, couples were to be referred immediately to mediation. Id.
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James J. Alfini, Trashing, Bashing, and Hashing It Out: Is This the End of “Good mediation”? FLA. ST. U. L. REV. , ( ). In Florida, mediation was used to resolve minor” criminal and civil cases in the s. Id. In , Florida’s first court connected ediation programs were established to resolve community disputes. Id.
Joshua D. Rosenberg, In Defense of Mediation, ARIZ. L. REV. , ( ) (citing PAM GULLIVER, DISPUTES AND NEGOTIATIONS: A CROSS-CULTURAL PERSPECTIVE – ( )).
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Marion Z. Goldberg, Divorce Mediation: Panacea or Just Another Tool? TRIAL, Sept.
Mediation by Alison Gerencser, Alachua County (Florida) Courthouse, Spring
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