"There is nothing worse than aggressive stupidity," (Johann Wolfgang von Goethe).

Throughout the history of family law litigation, parties have engaged in tactics that can be most kindly and favorably described as "bad behavior." Notably, there appears to have been an uptick in decisional law which not only describes the work of "bad actors," but which metes out justice in a manner that denotes an ever evolving and growing lack of tolerance by judges for the antics of those who would manipulate, coerce, threaten and harm (physically, emotionally or financially) the opposing spouse or opposing parent, the parties' children, family members, business interests, etc. All too often such behavior on the part of the bad actor is intentionally designed to place the other party at a psychological or informational disadvantage while simultaneously attempting to dominate the results of the dispute by force, subterfuge, intimidation, and the like. Examples of this type of bad behavior can be found in both the negotiation and the litigation contexts. This column will focus on recent case law reports describing examples of such behavior and the manner in which the courts have addressed it.