California Divorce Law...

The court can order outpatient counseling in the case of dispute that poses a significant danger to the best interest of the child child. The dispute may be between:

• Parent and parent;
• Parent and child;
• Parent and another party seeking custody or visitation; or
• Child and another party seeking custody or visitation; or

The court may consider any history of domestic violence in making this order.

Section 3190.

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