Domestic violence batterers who attend counseling sessions reluctantly, interested only in complying with a court order, usually possess very little motivation and have limited expectations for a positive therapeutic outcome. When clients have resistant attitudes, they make it difficult for the counselor to establish an initial liaison with them; however, counselors who are judgmental, critical, and confrontational also make it difficult for the clients to commit to the therapeutic process. The solution-focused approach may be a viable alternative for such cases, given its emphasis on building cooperative client-counselor relationships; however, few authors have discussed the particularities of doing this with court-ordered batterers. The authors formulated effective solution-focused principles to be used with this population, and they used a case study to illustrate their use.