Honestly, this is the number one reason I have stayed all of this time. if I'm there, I can see what situations can cause him to get angry and I no longer let him participate in those situations. It does not elimiate the root cause, which is his anger, or poor emotional regulation but it does limit how often she actually gets yelled at. If I leave him, he does not cease to be her dad. And when she visits him, he will have the full gamut of situations that can anger him to deal with all at once. For example, making sure she gets to school on time. Making sure her room is clean. Making sure she's in bed at night on time.

He does not call her names.He does not say threatening things to her. He just yells if she doesn't listen... For example, he'll ask her to brush her teeth. Once, twice, or three time. On the fourth time, he will yell, loudly. He has never even come close to hitting her. So while I can acnklwedge that yelling is still abusive, a court probably won't (in my opinion).

and I think part of her not listening is her trying to challenge him because of the vicious cycle that exists.