Dealing with difficult clients


Over the past year or so there have been numerous sessions regarding dealing with difficult people. I have attending presentations as part of ICL training, VLA training, and at the National Mediation and Family Law Conferences. Many of us have learned of the leading features of most of the personality types discussed particularly around narcissistic, histrionic, and borderline personalities.

This week I participated in a mediation that raised concerns for me that I have not been able to stop thinking about. I realize now that hearing about these issues in theory, is inadequate preparation for dealing with the real thing. I realize that the father in one of my mediations this week suffered from one of these, or more likely a combination of several, and I was not prepared for how to adequately handle this situation. My instinct told me from the first 5 minutes with the father that something was very different. I quickly discovered that my usual tool box of strategies and techniques was not enough!


Separation had been many years ago. There are two children who had lived primarily with the mother, but recently moved to live with the father. An intake session had been undertaken by a case manager, some weeks prior to the mediation conference. I had been provided with a detailed report setting out the answers that the parents had given to questions including those relating to background information, family violence, protective concerns and any previous negotiations. A recommendation had been made that the mediation proceed in a shuttle format.

Presentation of the father

The father stated that his preferred position was that the children continue to live with him, but he was willing to negotiate a return to the mother’s care on a shared care basis, if she would be able to reassure him that she could provide a safe environment for them in her care.

From the outset the father was very focused on the ways he had been wronged in the past, and any attempt by me to move towards what he would like to see happen in the future, were met by a strong response that he needed to tell me all these things for me to really understand what was happening for him and his children, and how I could assist him.

His descriptions of past events were centered on numerous and severe complaints against the mother, all the terrible things that she had done to him and the children, and the negative qualities that she had, that were being ignored by those who had been involved with the family in the past.

Any attempt to reframe past events into more neutral, mutual and child focused language, was immediately seized upon as evidence that he was not being taken seriously.

Any suggestions that there might be more than one explanation, and that the children themselves might have their own stories, were met with opposition and justification. He spoke of his involvement with the children’s counselor who he saw as vindicating his position and stance. He mentioned that he had made numerous disclosures to DHHS and that he continued to regard his children as being in serious danger every day that they were in the mother’s care. He described how there had been many attendances at court regarding IVO proceedings and that he had appealed the most recent orders and he was confident that the only remaining IVO against him would soon be dismissed. He was clear that if any professional did not do the right thing by him then he would take action to make sure that this was investigated further. He did not need legal advice or support, he regarded himself as quite capable of representing himself.

Attempts to discuss the needs of the children very quickly turned into a consideration of his own needs, as truly reflecting the needs of the children and being one and the same thing.

The mother

The mother presented as fragile and vulnerable. She described herself as emotionally exhausted, and feeling utterly uncertain of what she could do in the circumstances. She was unclear how her circumstances and those of the children had deteriorated so quickly to where things were at present. She was not prepared to negotiate in the same room as the father.

She was able to acknowledge that she had been unable to set clear boundaries and maintain these with the father, and that she had often given in to his demands for the sake of peace and harmony, and to minimize stress and trauma to herself and the children in the short term.

She was able to be child focused and could appreciate that if she found dealing with the father exhausting and difficult, that the children were likely to also be experiencing him in this light.

The mother accepted that there was probably little she could do to change the father’s behavior herself. She was also clear that she did not want to go to court. She was willing to engage in personal counseling to develop strategies to assist herself, and to provide good role modeling for the children.


The father indicated to me his requirements for an ongoing shared care arrangement. And the conditions that would have to be met for him to agree to this. He asked me to convey this to the mother and wished me luck in being able to negotiate an agreement.

The mother was prepared to agree to this in principle, for a trial period, and to return to review the arrangements after a period of time.

I told the father of the shared care arrangement that the mother had accepted and discussed with him the various conditions that would need to be in place for both parents to be confident that the children would be safe and comfortable with the arrangements. He immediately confronted me with his sense that I had spent only a very short amount of time with him, and an extremely long period of time with the mother. He wanted to know what I had discussed with the mother, what she had said. He told me that he would not agree to the arrangement that the mother had proposed, and indicated that he would not consider such an arrangement under any circumstances.

I then sought an indication from the father of what he would be prepared to agree to. He confirmed that he wanted to try out his ideas for a period of time and return to review them, rather than commit at that stage to anything more long term. We spent some time going through what he wanted, and putting this up on the board so that there could be no misunderstanding of what was being suggested. It became apparent to me that the proposal that we developed was essentially the same as that of the mother, apart from one of the overnights in the fortnight being on a different night of the week!

The Father asked me to convey this to the mother and get her lawyer to prepare a written version of the arrangement. I did this, moving between the parents to ensure that the father did not feel that he was being left on his own for lengthy periods, or that I was not being even handed in the process overall. Various details for timing, special occasions, special activities, and protective measures were discussed and agreed upon. Finally a Parenting Plan was drafted to incorporate these proposals. The mother signed, but at the last minute the father stated that he would not sign the document. He would comply with the agreement, but would not sign any document that had any legal significance or could be used against him. He denied the need for time to consult with legal representation.


I left this mediation feeling the need for further strategies to deal with the personalities involved. I realized that it is one thing to listen to a seminar about difficult people, and it is quite another to be able to deal with them.

When thinking back on this matter it is easy to regard the difficult parent as acting badly-being rigid, attacking, criticizing, manipulative and self-absorbed. It is suggested by Bill Eddy, an expert in this area, that high conflict behavior is not driven by logic and self-awareness, but unconscious defensiveness. [i] Giving negative feedback and expecting insight and behavior change, will only result in frustration and an increase in the negative behavior.

Bill Eddy describes the need to understand that bad behavior is defensive-a threat is perceived that results in the need for self protection.[ii] Those with personality disorders or traits of personality disorders often display bizarre thinking, unmanaged emotions and extreme behaviours. They have generally lived with these traits all of their lives, and do not have a sense that these are unusual or extreme.

Bill describes a key aspect of these personalities as a repeated Mistaken Assessment of Danger. They truly believe that they are in danger from those close to them or people in authority, and they attack these people as their Targets of Blame. This is not based on rational analysis and thinking, but a gut feeling. Early childhood relationship dangers have impacted on their sense of security and survival, or their genetic tendencies are reinforcing these excessive fears and consequential behavior.[iii]

Seen in this light:

Borderline personalities appear to have an unconscious and extreme fear of abandonment that drives clinging and raging behavior and tends to push people to abandon them;

Narcissistic personalities appear to have an unconscious and extreme fear of being inferior or helpless which drives extreme efforts to be seen as superior and to insult and demean others;

Antisocial personalities appear to have an unconscious and extreme fear of being dominated by others, which drives efforts to dominate, manipulate, deceive and harm others;

Histrionic personalities appear to have an unconscious and extreme fear of being ignored, which drives them to be constantly dramatic and intense;

Paranoid personalities appear to have an unconscious and extreme fear of being betrayed by those close to them, which drives them to assume plots and conspiracies, unwarranted grudges and attack others first to protect themselves.

If you accept that these personalities all have different unconscious fears that are based on a mistaken assessment of danger, and results in their aggressively defensive behavior, then by reducing the mistaken assessment there will not be a need to defend themselves and no need for the aggressively defensive behavior.


If the impetus for the inappropriate behavior is a life long mistaken assessment of danger, then negative feedback that is emotionally threatening will not be helpful at all. You must interact with the person in such a way to reduce their fears, and this interaction must be tailored to the type of personality you are dealing with: [iv]

With the borderline, you must maintain a moderate, even tempered manner that is not rejecting;

With the narcissistic client, you must try to avoid any insults and try to find things you can respect about that person;

With an antisocial type, you must be cautious not to believe their stories of victimization but at the same time avoid any sense of dominating them in verbal interactions;

With histrionic personalities you should try to pay brief attention to their dramatic stories, then gently focus on the task or topic at hand, and end the conversation by explaining you have to leave;

With paranoid clients, just be matter-of-fact and focus on what the rules are and why you have to follow them.


Bill Eddy recommends that you show empathy and concern for the person, and explain the rules or reasons why the specific behaviour needs to stop, and what the consequences are if it continues. The key is to help the person accomplish the goal that was underlying the bad behavior.[v]

Negative feedback is taken extremely personally and feeds the mistaken assessment of danger and in turn triggers more bad behavior. The focus must be on reducing emotional threats and on matter-of-factly setting limits on the behavior.[vi]

Bill Eddy states behavior change is possible by consisitently applying his three rules:

  1. Reduce the Mistaken Assessment of Danger
  2. Set limits on Behaviour that’s Aggressively Defensive
  3. Avoid giving negative feedback

Neuroplasticity will then, with effort and time, change the brain and with it the offending behavior.[vii]


In 6 months time this family may return to mediation to review the success of their agreement and to determine further mutually acceptable ongoing arrangements.

I have had an opportunity to consider the presentation of the father in this setting, and I feel that he appears to be a mixture of narcissistic and antisocial personality traits.

If I am right, then using the insight from Bill Eddy’s approach, I will firstly need to consider how I can reduce his mistaken assessment of danger in this setting. I will need to stress the things that I can respect about him. This will not be hard as he is clearly a very dedicated and devoted father and wants to have good quality time with his children to support them in important aspects of their lives. I will listen to his stories of being victimized, and avoid dominating him in discussions by listening actively to what he has to say, but providing a clear structure around the goals of the mediation session to keep our discussion on track.

I will then attempt to set limits on his aggressively defensive behavior. Having listened to him with empathy and concern, I will inform him of the rules and reasons why some of his behavior is inappropriate, and what the consequences will be if this continues. Some of the topics I might cover in this way would include the need for the children to have a good relationship with both parents, and that this need should be actively promoted by both of them. I might discuss the impact on the children of conflict between their parents, and of being exposed to negative comments about those who are important to them. I would focus on his goals for his children and assist with information and support for how these might be achieved in the most appropriate manner.

Finally, I would ensure that I do not provide any negative feedback. I will try to work with him to explore ways that any emotional threats could be reduced, but at the same time consider the need to respect limits on behavior and appropriate boundaries.

If you have had recent experiences of working with difficult personalities, I would be very interested to discuss these with you. I have recently acquired 2 books written by Bill Eddy “So what’s your proposal? Shifting high conflict people from blaming to problem solving in 30 seconds” and “Splitting-protecting yourself while divorcing someone with borderline or narcissistic personality disorder”. I would value engaging in a conversation around these issues that are presenting more and more often in our work an the insights from this material.



[i] “Dealing with Defensiveness in High Conflict People” by Bill Eddy page 1/5 found at

[ii][ii] Ibid page 2/5

[iii] ibid page 3/5

[iv] ibid page 3-4/5

[v] ibid page 4/5 paragraph 2

[vi] ibid page 4/5 paragraph 3

[vii] ibid page 4/5 paragraph 4

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