The Nudity Was Never the Risk Factor
When child safety becomes a convenient excuse to target a parent’s lifestyle.
An Ontario judge recently issued a temporary order banning an eleven-year-old girl from attending nudist camps with either parent and grandparents. The case had real, messy facts: a man who frightened the child was removed from a resort for inappropriate behavior, a child who said in her own handwritten notes that she didn’t want to go back, mostly, by her account, because of bug bites and a lack of privacy, and two parents who’d already been dragging each other through family court for years. It’s a complicated story, and we’re not here to pretend the judge got everything wrong. A child who says she (he)’s scared and doesn’t want to go deserves to be heard, full stop.
What we keep coming back to is a narrower question. Strip away the custody fight and the history between these two parents. Just look at the actual sequence of events: a man behaved inappropriately around a child, the institution identified him and threw him out, and a court then restricted the child’s access to an entire category of recreational space instead of just banning the man himself. Would that have happened if the same man had behaved the same way at a public pool, a soccer practice, or a church potluck? We’ve talked about this a lot since reading that decision, and the honest answer is… it wouldn’t have.
We see a specific playbook running here, one that more than one parent in our community has lived through. In a high-conflict custody dispute, an unfamiliar environment is an easy thing to turn and use against someone. When the incident happens somewhere mainstream, like a community center or a youth soccer league, the space itself stays innocent by default. A bad actor surfaces, he gets removed, everyone agrees it was one bad apple, and nobody suggests the kid should never play soccer again. But when the same kind of incident happens somewhere a judge, or a hostile ex, is already a little uneasy about, the venue itself becomes the story. The bad actor stops being the point. The place he was in becomes the point, and that’s a gift to the parent trying to argue the other one has bad judgment.
The Numbers Nobody Wants to Think About
Let’s talk about where children are actually, statistically, at risk, because it’s rarely where the family courts focus their suspicion.
The U.S. Department of Education’s Office for Civil Rights found close to 15,000 incidents of sexual violence in K-12 schools in a single recent reporting period, up more than 50 percent from two years earlier. A broader estimate put the number of students experiencing some form of sexual misconduct at school, including being shown pornography or otherwise sexually exposed by an adult, at roughly 4.5 million, about 10 percent of all students. A landmark federal investigation into education misconduct found that teachers accused of abuse were passed between an average of three school districts before anyone actually intervened. That means three different employers handed a predator a fresh start somewhere else rather than stopping him.
Churches don’t come out ahead. A massive investigation by the Houston Chronicle found roughly 380 Southern Baptist leaders and volunteers facing allegations, with over 700 victims since 1998, and a subsequent report commissioned by the SBC itself confirmed decades of systemic cover-ups. The Catholic Church’s numbers dwarf that: more than 15,000 survivors have come forward since 2009, with over $3 billion paid in settlements. An Associated Press investigation found nearly 1,700 priests considered credibly accused of abuse living with little to no oversight, some teaching school, some living next to playgrounds.
We are not naive enough to think naturism is some statistically risk-free zone full of saints. No community made of human beings is. But nobody is tracking naturist-resort incident rates with anything like the rigor that’s been poured into school and church abuse, because nobody thinks the institution is worth the investigative budget. That gap is itself a kind of evidence. We count what we already suspect, and we don’t bother counting what we’ve already written off as fine.
What the Law Actually Says (When It’s Not About Us)
Family courts have a well-established standard for handling disputes over a parent’s religious practices with their kids, and it doesn’t involve banning church and sorting it out later. Courts have repeatedly held that a parent’s religious practices, even ones the other parent hates, can’t be restricted unless there’s actual evidence the practice harms the child. We found the exact same logic playing out in places like Ohio, Texas, and Virginia. The pattern holds across jurisdictions: courts intervene on proven harm tied to a specific practice or person, not on a category of activity they happen to be personally squeamish about.
Now imagine the equivalent order in a school or sports context. “Pending further information, neither parent may enroll the child in public school,” issued after a teacher was credibly accused and fired. “Neither parent may allow club soccer,” after a coach got removed for inappropriate conduct. No family court anywhere would write that. It would sound absurd on its face, because the only sane response is to restrict the person, not the institution. You don’t ban swimming because one swim coach turned out to be a predator. You ban that coach.
That is, word for word, what happened with the man at the Ontario resort. He was identified. He was removed. The system worked exactly the way it’s supposed to. And the remedy the court reached for wasn’t “stay away from him.” It was “stay away from places like this.”
Looking for Precedent
We went looking for whether any court, anywhere, has actually settled this question on appeal. We checked Canada, the UK, Germany, France, Australia, and New Zealand. In five out of six places we looked, we found nothing. No appellate court in any of those countries has ever directly ruled on naturism and custody as its own category. The Ontario order may be one of the only written judicial decisions anywhere that engages with it head-on, and it’s a temporary order from a lower court, not binding on anyone else, not even in Ontario.
The US is its own mess, because there isn’t really a single “US standard” to check against. Custody law is set state by state, and we found the same pattern playing out informally rather than through any clean appellate ruling: naturism showing up as a credibility weapon in individual custody and foster-placement disputes, decided case by case, judge by judge, with wildly inconsistent results depending on where you happen to live.
Florida is widely considered the most naturist-friendly state in the country, home to massive, economically vital clothing-optional communities and major destination resorts. Yet, a regional state child welfare contractor there instituted a blanket policy refusing to place foster children with anyone living inside a nudist community. It was a category-wide exclusion made by an administrative agency, not a judge weighing actual facts about a specific home or a specific child. That’s the American version of the same instinct driving the Ontario order, just with less due process attached to it, since it never had to survive a hearing or a written decision to take effect.
The one exception is France, and it’s the most interesting result of the bunch precisely because France has one of the most normalized naturist cultures on earth. Families make up close to 80 percent of the clientele at French naturist resorts. You’d think that level of mainstream acceptance would mean the legal question never comes up. Instead, French family law commentators describe a recurring pattern almost identical to what we’re talking about here: a couple practices naturism together without conflict for years, then separates, and the same activity that was never an issue during the marriage suddenly becomes grounds to restrict the naturist parent’s access, or fuel for a fault-based divorce, or both. One commentator who tracks this area of law put it plainly, that naturism remains a live issue in French family courts and shows no sign of going away.
That result changes the shape of the argument a little. It would be tidy to say courts only turn on naturism where the culture treats it as fringe, and that normalization is the fix. France shows that’s not quite right. Even in a country where naturism is about as unremarkable as it gets, the activity still gets weaponized the moment two parents become legal adversaries. What seems to actually drive this isn’t unfamiliarity with naturism specifically. It’s that divorce turns every unconventional thing a couple used to do together into a potential weapon, and naturism is an easy one to reach for, because it’s visible, it’s photographable, and it’s simple to make sound alarming to a judge in a single sentence, whether or not the judge has ever set foot in a naturist resort.
Codes of Conduct: Who’s Actually Covered
We went looking for what churches require of the people who walk through their doors, expecting to find something comparable to what naturist clubs ask of their members and guests before they’re even let onto the property. What we found instead was more telling than a simple lack of rules.
Churches absolutely have child protection policies now, from the Catholic Church’s Essential Norms to individual congregations’ background-check requirements and photo policies. Some of this is genuinely thorough. Every single one of these policies is scoped to people with an institutional role, like staff, clergy, and volunteers. The ordinary person in the pew, who’s never volunteered for anything, is simply outside the system. He can be alone in a hallway with a child and there is no institutional mechanism that ever applied to him in the first place.
A naturist club’s code of conduct doesn’t work that way. It applies to every adult on the property the moment they walk in, member or first-time guest, board member or nobody in particular. That’s a wider net by design, because a clothing-optional space simply doesn’t function without it. The man at the Ontario resort wasn’t an employee or volunteer. He was just an attendee, and the club’s own code of conduct, the kind that covers everyone, is what got him removed.
The timeline should bother people more than it seems to. The Catholic Church has existed for roughly two thousand years. The Southern Baptist Convention since 1845. Enforceable, codified child protection policy in either institution didn’t show up until 2002 and 2019 respectively, and in both cases it took journalists, lawsuits, and insurance carriers threatening to walk away to make it happen. That looks less like evolution and more like an institution operating for centuries with no formal safety mechanisms until it became financially impossible to ignore.
Organized naturism is barely a hundred years old, and screening norms and basic boundaries got built in almost from the start. That kind of structure exists because the lifestyle doesn’t survive without it. We’re not interested in dragging religion through the mud here. Most congregants never hurt anyone and most clergy are exactly who they appear to be. But the institutional comparison is what it is: the newer, smaller, less powerful community built its safeguards proactively. The older, larger, more trusted ones built theirs only once they got caught.
Proving a Negative
So what would it actually take for a parent to prove that nudity itself doesn’t harm a child? We genuinely don’t know how you’d build that case, because nobody has ever shown the opposite either, and we mean that more literally than it might sound.
Start with the oldest result. Oleinick and colleagues looked at this back in 1966 and found no relationship at all between childhood nudity exposure and later psychiatric symptoms. Lewis and Janda picked the question back up in 1988, and here’s the part worth noticing… they expected to find harm. They went in hypothesizing that exposure to nudity in childhood would predict worse adjustment, more criminal behavior, weaker relationships, the assumptions most people still carry around today.
Instead they found exposure was modestly, positively related to adjustment. The UCLA Family Lifestyles Project went looking for the same thing a decade later, an 18-year longitudinal study following 200 kids from early childhood into young adulthood, the gold standard for this kind of research because of how long they tracked the same children. Same expectation going in, same result coming out: no harmful effect from exposure to parental nudity, with the data trending toward beneficial rather than neutral. An earlier, more narrowly focused study from 1979 looked specifically at kids from families that identified as social nudists and found the opposite of harm, more positive body concepts, not less.
And the most recent entry, a 2023 study funded by the International Naturist Federation and British Naturism, surveyed both adults recalling their own childhoods and, separately, mothers and children reporting on the children’s current experiences in real time. Same finding again: no evidence connecting childhood nudity to negative outcomes, with some indication that kids raised in nudity-normalized households may have better body image than kids who weren’t.
That’s roughly sixty years of research, multiple countries, multiple unconnected research teams, several of whom built their studies expecting to confirm the harm everyone assumes is there, and not one of them found it.
There’s one wrinkle worth being honest about so nobody else gets to use it against us first. The UCLA study found a single secondary effect, not about nudity, but about children who witnessed actual parental sexual activity before age six, where girls in that specific subgroup showed an increased risk later on. That’s a real finding, but it’s measuring something else entirely, and conflating witnessed sex with simple nudity is exactly the kind of sloppy variable-mixing that critics of this research, fairly, have pointed to.
The one legitimate methods complaint about this whole body of work is that early studies sometimes lumped nudity in with things like that, which makes it harder to isolate exactly what’s doing the work. That’s a fair request for cleaner data. It is a very different thing than a finding that someone got hurt.
Compare that to the language the judge used in the Ontario decision, erring on the side of caution “unless and until the court is provided with more objective and detailed information.” That phrase is doing a lot of quiet work. It’s a precautionary default standing in for evidence that doesn’t exist, and it quietly flips the burden of proof. In a dispute over mainstream or religious practices, the parent alleging harm has to prove it. In a naturism case, the naturist parent is the one stuck trying to prove a negative, that an entire category of family life poses a risk that medicine and psychology have never been able to document.
As we said at the beginning, a child who says she (he)’s scared deserves to be listened to and protected, every time, no exceptions. But protecting a child from a specific man who behaved badly and restricting a child from an entire category of recreation her family has safely practiced for years are completely different sentence. Yet courts keep writing them as though they are the same.
We don’t know what it would actually take to change that. Probably a few more rulings that get pushed back on, a few more families willing to put their names on it, maybe nothing at all for a long time.
We just know it isn’t going to change soon… because the data is already sitting there. It hasn’t moved anyone yet.
Kevin and Corin
Editor’s Note Added July 1, 2026:
Since publication, we obtained the full text of the Ontario decision referenced in this article (N.G.M.B. v. S.T.C., 2026 ONSC 2320). A few clarifications are worth noting for accuracy.
The naturist resort attended by the family was located in Michigan, not Canada. The judge himself acknowledged in his decision that his independent research confirmed “a dearth of Canadian caselaw” on children attending naturist resorts, which validates our finding that settled precedent is nearly absent. Two older Canadian cases were referenced in the decision: Renwick v. Renwick (1982, Saskatchewan QB) and Children’s Aid Society of Sudbury & Manitoulin v. B.(D.) (2008 ONCJ), both lower court decisions that did not produce binding appellate precedent.
Notably, AANR executive director Eric Schuttauf testified as a witness for the mother in this case, as did Bare Oaks owner and INF president Stéphane Deschênes.
The judge was careful to state that naturism itself was not on trial, and grounded his temporary order primarily in this specific child’s diagnosed PTSD, anxiety and depression, the conflicting accounts of her wishes, and the years-long non-disclosure of the naturist activities to the father.
The core argument of this article, that courts apply a categorical suspicion to naturism they don’t apply to other institutions, remains our position, and nothing in the full decision changes that.
One section of the ruling deserves specific scrutiny. The judge argues that enhanced security protocols at naturist resorts exist precisely because nudity creates elevated risk, and therefore the elevated risk is real and inherent to the setting. That reasoning is circular in a way the judge doesn’t appear to notice. Churches, schools, and youth sports organizations all operate under enhanced security protocols now too… background checks, two-adult rules, photography bans, mandatory reporting requirements. By the judge’s own logic, those protocols exist because elevated risk is inherent in those settings as well. He doesn’t extend that inference to any other institution. He extends it only to naturism.
More troubling, his claim that a naked girl alone with a naked male stranger is inherently more dangerous than a clothed girl alone with a clothed male stranger is stated as self-evident. He cites no study, no criminological data, and no expert testimony to support it. It is the judge’s own intuition presented as legal reasoning, and it is precisely the kind of unevidenced assumption that the research we cited in this article was designed to address. The experts who could have challenged it directly were sitting in his courtroom. Nobody asked them.
If you wish to read the full decision: https://www.minicounsel.ca/scj/2026/2320
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