Forensic Psychologist, Deirdre Conway, Rand, PhD

This article reviews the literature on the Parental Alienation Syndrome (PAS) as formulated by Dr. Richard Gardner and seeks to integrate his work with research on high conflict divorce and the work of other professionals in this arena. Parental Alienation Syndrome (PAS) is a distinctive form of high conflict divorce in which the child becomes aligned with one parent and preoccupied with unjustified and/or exaggerated denigration of the other, target parent. In severe cases, the child's once love-bonded relationship with the target/rejected parent is destroyed. Part II begins with sections on the child in PAS, the target/alienated parent and the third parties who become involved, including family, friends, lawyers, mental health professionals, and sometimes cults. The material presented on PAS in the legal arena is devoted to what attorneys and judges have to say about PAS, which can be a key issue in certain depend ency and criminal proceedings, as well as in family law court. The discussion of forensic evaluations and PAS includes contributions by custody evaluators and others who recommend considering PAS as a possible explanation when child sex abuse is alleged in certain contexts. Case vignettes in Part II illustrate psychological maltreatment of the child in severe PAS, a case in which Child Protective Services was mobilized to bring pressure on the alienating parent to reverse the PAS, and the use of PAS testimony in criminal proceedings against a falsely accused parent. Part III will be devoted to interventions in PAS, including some difficult but effective interventions implemented by the author, her husband, Randy Rand, Ed.D., and a team of interveners, including the judge and guardian ad litem.

The Parental Alienation Syndrome (PAS) as formulated by Gardner involves a cluster of child symptoms in divorce. Gardner views these as a syndrome because of the number of cases in which these symptoms share a common underlying etiology. This is a combination of the alienating parent's influence and the child's active contributions to the campaign of denigration against the alienated/target parent. The term PAS does not applywhen children of divorce become alienated from a parent for reasons such as a parent's lack of interest in or rejection of the child; significant deficits in a rejected parent's functioning which may not rise to the level of abuse; or the child being subjected to bona fide parental abuse or neglect. These situations should be given the generic label of parent-child alienation. The Parental Alienation Syndrome as conceived of by Gardner is a type of parent-child alienation but warrants a special descriptive term. The benefit of using Gardner's terminology is that, where the facts of a given case support a diagnosis of PAS, there is a body of knowledge regarding which legal and therapeutic interventions are likely to be effective.

Part I of this article, published in a previous issue of the American Journal of Forensic Psychology (Volume 15, issue 3, 1997), outlined Gardner's formulation of PAS, discussed the contemporary social context in which his ideas arose, and described the features of PAS which, especially in more serious cases, make it a distinctive form of high conflict divorce. The studies reviewed in Part I included a large scale research project by Clawar and Rivlin, which was commissioned by the American Bar Association Section on Family Law (1). Clinical studies of PAS by Dunne and Hedrick (2), Lund (3) and Cartwright (4) were also discussed. Two case vignettes were presented, one in which the mother was the alienating parent and the other with the father in that role. Part I concluded with a section on parents who induce alienation, utilizing divorce research and the work of mental health professionals who deal with divorce families in the forensic arena. Part II begins with the child.

THE CHILD IN PAS

Children of Divorce

Most children and adolescents of divorce are eager to have an ongoing relationship with both parents. In a nonclinical sample of 131 children from 60 divorce families, the majority of children were eager to visit their noncustodial fathers and often wanted more time than the usual every other-weekend allowed (5). This finding held at follow-ups 18 months and 5 years later. For children whose fathers did not take much of an interest in them, their longing for both parents was very painful. Where the father did take an interest, 20 percent of children were in considerable conflict about visiting and 11 percent were genuinely reluctant to visit, most notably those who were between 9 and 12 years of age. Nineteen percent of the children who were reluctant or refusing to visit were aligned with one parent in actively doing battle against the other parent. Children in these alignments came to share the views and outrage of the parent with whom the child identified, often the parent who felt abandoned and rejected in the divorce. These children rejected the parent who was perceived as deserting the family, despite a previously close, loving relationship with that parent. Children in alignments were found to be less psychologically healthy than those whose divorce adjustment allowed them to maintain their affection for both parents.

Children's Alignments in High Conflict Families

Johnston and Campbell's research on divorce families in high conflict for three years or more found a measurable degree of alignment between children and one parent in 35 percent to 40 percent of children from-7 to 14 years of age (6). Similar ratios were obtained by Lampel, who studied latency-age children participating in custody evaluations ( 7). Comparing aligned children with non-aligned children, Lampel found that the aligned children tested as angrier, less well adjusted, and less able to conceptualize complex situations. They expressed greater self confidence, however, possibly reflecting the relief obtained by opting for a simplified, relatively black-and-white solution, as opposed to feeling "caught in the middle" of parental conflicts. Published in 1996, this article of Lampel refers to Gardner's work on PAS.

Children Who Reject One Parent

Ten years earlier, Lampel reported on 18 consecutively referred high conflict divorce families, including a group of children who actively rejected one parent (8). In these seven cases, the rejected parent was the father. Lampel found the child's lack of normal ambivalence noteworthy in these seven cases and further observed intense collusion between mother and child. Lampel implemented a family intervention strategy which treated these children's reactions as a phobia with hysterical features. One child who was placed with the rejected parent for six to eight weeks while Lampel worked intensively with all family members reported a marked reduction in symptomatology. Of the remaining cases treated with phobia reduction techniques, results ranged from minor improvement to deterioration. In the three cases where intervention clearly failed, Lampel concluded it was because the mother's collusive involvement with the child was too strong.

Children Who Refuse Visitation

According to Johnston in 1993, "It is surprising that such a perplexing and serious problem as children's refusal to visit has received so little systematic attention by researchers" (9; p. 110). In a study focused specifically on this problem, Johnston recognized Gardner's work on PAS. Results of research by Johnston and her colleagues led to the conclusion that children's resistance or refusal to visit a nonresidential parent after separation and divorce is an overt behavioral symptom that can have its roots in multiple and often interlocking psychological, developmental and family systemic processes. Clawar and Rivlin articulated similar findings in their study published two years earlier (1).

Developmental Issues of Children Who Refuse Visitation

Analysis of data from 70 high conflict divorce families enabled Johnston and her colleagues to identify specific developmental issues for each age group which can impact children's reluctance and refusal to visit. Emotional disturbance of the primary parent, usually the mother, was found to exacerbate developmental effects. For 2- to 3-year-olds, age appropriate separation anxiety from the mother was found to be a factor in resistance to visitation. In normal development, children this age have not yet developed an internalized image of the primary parent figure.

Their sense of time is not yet sufficiently developed for them to understand that they will be getting back to the primary parent within a comfortable time frame. Parents may blame each other when children this age display resistance to visitation, even though such problems may be due in part to developmental factors.

Johnston found that 3 to 6 year-old children in high conflict divorce tended to shift their allegiances depending on which parent they were with. This may contribute to children's difficulty in transitioning from one home to another. Normally, children in this age group have not yet learned to entertain two conflicting points of view. As a result, when the child is told in mother's home that father does not provide enough money, the child will temporarily align with mother. The child will shift allegiance to father when told in his home that mother just wastes the money. Children from 3-6 years of age become easily confused and can readily excite concern and chaos by telling different stories to each parent. In addition, the normal course of development is for children's preferences to shift back and forth from one parent to the other as they grow older and sort out their gender identity. Children in the 3-6 age range experience a strong drive to align with the opposite sex parent and to compete with and to exclude the same sex parent. In divorce, the young child's developmentally normal fantasies about eliminating the same sex parent may be fulfilled. This creates intense guilt and anxiety for the child, which can contribute to resistance to visitation.

Children of divorce in the 6- to 7-year age range are more likely to suffer from loyalty conflicts, and to be concerned about hurting their parents. Such conflicts reflect the normal child's growing sense of morality and capacity to see things from the viewpoint of another. Children 7 to 9 years of age have begun to develop the capacity to imagine how their parents view them and to experience the cognitive dissonance of their parents' conflicting views. There may be a growing need to resolve such conflicts because children in this age range experience the loyalty conflicts of divorce more acutely.

High conflict divorce children in the 9- to 12-year-old group are particularly vulnerable to forming strong, PAS type alignments with one parent, as they try to "resolve" their earlier loyalty conflicts. Johnston noted that adults also tended to expect more children this age, viewing them as "old enough to take a stand" in parental disputes. Forty-three percent of these children were in strong alignments and 29 percent in mild alignments. According to Johnston, these figures approach Gardner's estimate that 90 percent of the children he has assessed in custody evaluations exhibit varying degrees of PAS. Johnston found that in some cases, parent-child alignments often continue for several years into mid-adolescence. As teenagers, some aligned youngsters develop the capacity to take a more objective, independent stance. However, a significant proportion of high conflict divorce children are unable to withdraw from the parental fights and maintain their stance of rejection and denigration toward the target parent throughout adolescence.

Strong Alignments

Johnston found that 28 to 43 percent of the 9- to 12-year-olds were in what she termed "strong alignments," characterized by consistent rejection and denigration of the other parent (9). Children tended to make stronger alliances with the more emotionally dysfunctional parent, who was more likely to be the mother. In Impasses of Divorce, Johnston described children in strong alignments as forfeiting their childhood by merging psychologically with a parent who was raging, paranoid, or sullenly depressed (6). Factors within the child which contributed to the formation of strong alignments were found to be: 1) need to protect a parent who was decompensating, depressed, panicky or needy; 2) need to avoid the wrath or rejection of a powerful, dominant parent (often the custodial parent on whom the child was dependent; and 3) need to hold onto the parent the child was most afraid of losing, for example, a parent who was too self-absorbed or who was only casually involved with the child.

Extreme Alignments

Among children who were refusing visitation, Johnston identified a particularly troubled group of children whom she described as being in "extreme alignments"(9). In her most recent book, she and Roseby reserved Gardner's label "parent alienation syndrome" for these cases (10). Children in extreme alignments were more likely to be viewed as disturbed by parents, teachers and clinicians (9). These children exhibited bizarre and sometimes destructive behavior. They were more likely to display unintegrated, chaotic attitudes with few workable defenses. Often the child's negative interpretation and distortions of the target parent's character and behavior were found to have a bizarre quality (6, 9). The case vignette of Mr. and Mrs. C in Part (I) I described how the behavior of their daughter, V, became increasingly bizarre and self-destructive especially after her father gained sole custody in dependency court based on false allegations of sexual abuse against Mrs. C's new husband.

Pseudologia Fantastica

Once separated from her mother, V's stories of abuse by her stepfather became Rmore numerous and improbable, including charges of repeated rape although the gynecological exam was normal. Bernet suggested that. the century-old conceptof pseudologia fantastica is one explanation for elaborate, implausible, untruthful reports of abuse (11). Children who exhibit pseudologia fantastica, represent certain fantasies as if they were actual occurrences, although there is little or no reality basis for these stories. Ditrich posited that children who engage in pseudologia fantastica do so in order to defend against the pain of an unbearable, present reality (12). V engaged in pseudologia fantastica in part to cope with the unbearable loss of her mother, who had been the primary parent. Her father, Mr. C was so driven by his need for revenge against V's mother that he encouraged and reinforced V's use of pseudologia fantastica instead of providing reality testing.

Failed Separation-Individuation

In a recent book chapter entitled "Parental Alignments and Alienation Among Children of High Conflict Divorce," Johnston and Roseby opined, "Rather than seeing this syndrome as being induced in the child by an alienating parent, as Gardner does, we propose that these 'unholy alliances' are a later manifestation of the failed separation-individuation process in especially vulnerable children who have been exposed to disturbed family relationships during their early years" (10; p. 202). These disturbed family relationships are viewed as the byproduct of interparental conflict and narcissistic disturbance of one or both parents. These authors hypothesize that the more extreme forms of parent alienation in early adolescence have their roots in failed separation-individuation from the alienating parent during the earliest years of the child's life. This developmental failure adversely affects the young person's life and developing sense of self. The most important ingredient in certain severe parental alienation cases, according to Johnson and Roseby, is the child's vulnerability and receptivity to the alienating parent, rather than "conscious, pernicious brainwashing" by an embittered parent.

In contrast to this view, mental health professionals practicing in the forensic arena often find evidence of substantial volitional activity on the part of the alienating parent in severe PAS. For example, in the case of Mr. and Mrs. L in Part I, the custody evaluator and others observed that the mother timed her suspected abuse report to authorities in such a way as to prevent father's visitation from going forward. Mrs. L was also observed to make denigrating remarks about Mr. L in front of the child. Whether or not these behaviors were "conscious"or "unconscious," Mrs. L was the person responsible for them and they did impact the child's relationship with the father.

Important Deviations From Usual Developmental Trends

When children who are resistant to visitation deviate from usual developmental trends, it is important to evaluate and understand the reason. Children who form consistent alignments with an alienating parent may never have separated psychologically from that parent (9, 10). Examples of this are described by Dunne and Hedrick in their study of 16 severe PAS families (2), which was reviewed in Part I. There are a variety of contributing factors to children forming strong parent-child alignments before the highest risk period of 9 to 12 years of age. These factors include: 1) a failed separation-individuation process between parent and child; 2) intense parental pressure; 3) a child with precocious cognitive development who is more sensitive and vulnerable to parental conflict. Children can become aligned with one parent even though there is relatively little overt conflict and estrangement between the parents (9). Seemingly mild and subtle forms of parental influence can have significant effects, according to Clawar and Rivlin (1).

Child's Active Contributions in PAS

The fact that Gardner identifies the child as an active participant in the PAS is sometimes overlooked. Active contributions by the child can be part of an effort to take care of an angry, disturbed, or otherwise troubled parent with whom the child is aligned.

Some PAS children manipulate conflicts between the parents for the feeling of power it gives them in the divorce family situation which is otherwise beyond their control. Young adolescents in search of greater freedom may amplify their complaints about a stricter parent to the more our missive one, capitalizing on the permissive parent's eagerness for validation of his or her fixed negative view of the other parent. This reinforces the permissive parent's inability to contain the child and exacerbates acting out behavior. Regardless of the relative contributions to the PAS by the alienating parent or the aligned child, a mutually reinforcing feedback loop may develop which is resistant to outside influence and to reality testing. A self generating "brainwashing "process results.

In Munchausen syndrome by proxy (MSP) involving older children, it is the parent who originally initiated the child's factitious illness or victimization. In the context of a continued symbiotic parent/child relation ship, older children may then learn to set up this situation themselves, producing factitious symptoms which induce a complicitous response from the MSP parent (13). Similarly, in moderate to severe PAS, children may learn to get their needs met by fabrication and manipulation. Where there is a particularly enmeshed relationship between the aligned parent and child, the child's legitimate strivings for autonomy are continually under mined.

The Overburdened Child

Divorce almost inevitably burdens children with greater responsibilities and makes them feel less cared for. Children of chronically troubled parents bear a greater burden. They are more likely to find themselves alone and isolated in caring for a disorganized, alcoholic, intensely dependent, physically ill, or chronically enraged parent. The needs of the troubled parent override the developmental needs of the child, with the result that the child becomes psychologically depleted and their own emotional and social progress is crippled. Wallerstein and Blakeslee used the term "overburdened child"to describe this problem (14). Wallerstein has encountered PAS [personal communication to the author, 1991], but she prefers to conceptualize it from the "overburdened child"framework.

The Psychologically Battered Child

According to Garbarino, et al., psychological maltreatment of children is more likely to occur in families where the atmosphere is one of stress, tension and aggression (15), an apt description of high conflict divorce. The Psychologically Battered Child, published in 1988, does not mention divorce directly but uses such terms as "marital discord"and "family breakdown." The special problems of children of divorce are more fully recognized in a subsequent book by Garbarino and Stott, in which Gardner's work is cited numerous times, including his work on PAS (16).

According to Garbarino et al., psychological maltreatment can be viewed as a pattern of adult behavior which is psychologically destructive to the child, sabotaging the child's normal development of self and social competence (15). Five types of psychological maltreatment identified by Garbarino et al. are adapted for PAS and described below:

1) Rejecting - The child's legitimate need for a relationship with both parents is rejected. The child has reason to fear rejection and abandonment by the alienating parent if positive feelings are expressed about the other parent and the people and activi ties associated with that parent.

2) Terrorizing - The child is bullied or verbally assaulted into being terrified of the target parent. The child is psychologically brutalized into fearing contact with the target parent and retribution by the alienating parent for any positive feelings the child might have for the other parent. Psychological abuse of this type may be accompanied by physical abuse.

3) Ignoring - The parent is emotionally unavailable to the child, leading to feelings of neglect and abandonment. Divorced parents may selectively withhold love and attention from the child, a subtler form of rejecting which shapes the child's behavior.

4) Isolating- The parent isolates the child from normal opportuni ties for social relations. In PAS, the child is prevented from participating in normal social interactions with the target parent and relatives and friends on that side of the family. In severe PAS, social isolation of the child sometimes extends beyond the target parent to any social contacts which might foster autonomy and independence.

5) Corrupting-The child is missocialized and reinforced by the alienating parent for lying, manipulation, aggression toward others or behavior which is self destructive. In PAS with false allegations of abuse, the child is also corrupted by repeated in volvement in discussions of deviant sexuality regarding the target parent or other family and friends associated with that parent. In some cases of severe PAS, the alienating parent trains the child to be an agent of aggression against the target parent, with the child actively participating in deceits and manipulations for the purpose of harassing and persecuting the target parent. This is particularly likely to occur in what Turkat called Divorce Related Malicious Parent Syndrome (17, 18).

Psychological maltreatment can be mild, moderate or severe. Effects on the child may vary according to the child's age, temperament and ability to access social support.

Children who have been psychologically maltreated by the primary caretaker on whom they depend are more likely to exhibit a variety of psychological and social handicaps. These make them vulnerable to detrimental outside influences. A case of psychological mal treatment by the alienating parent is illustrated below.

Case Vignette of Psychological Maltreatment in Severe PAS

At 13, S was a socially isolated girl who believed she was stupid. She spent recesses alone because the other kids did not accept her. She got "D "grades in school. For as long as she could remember, her mother told S she was incompetent and unlivable. S's mother would tell her, "Even your baby half sister is smarter than you are ". S hadn't seen her father in 10 years. Her parents separated when she was only a few months old. Her father quickly found a new partner and remarried. Although S's mother tried to stop father's contact with the girl, father and his new wife visited with S regularly until she was three. At that time, mother was successful in persuading child protective services to stop the visitation based on allegations of sexual abuse.

Father turned to the family court for help. A custody evaluation was conducted which exonerated the father of abuse charges and indicated that the mother was using the abuse allegations to prevent the child from having a relationship with her father. After several years of family law litigation, the judge ordered reunification and appointed a reunification therapist. For the next three years, the efforts of the reunification therapist and family court mediator were thwarted by the mother. Father became depressed and entered individual therapy.

A break in the case came when S's father was referred to a PAS expert for consultation. The family mediator, reunification therapist and the court were interested in the expert's input. The judge ordered mother and daughter to meet with father's PAS expert to facilitate the father/daughter reunification. The court also threatened mother with sanctions when she refused to cooperate with the reunification plan. The reunification team, which now in cluded a guardian ad litem for the child, planned to gradually reacquaint S with her father. The Read More .. gradual approach proved unsuccessful. The child remained hostile and staunchly aligned with her mother.

The team agreed that a different approach was needed. The PAS expert held a meeting with S and the reunification therapist. The expert established rapport with S, who was guarded but responsive. He asked S questions and gave her information which made her curious about her father. S indicated that she was interested in exploring the contradiction between her belief that father molested her and her lack of any actual memories of molestation. This opened the door for the expert to provide age appropriate education about the concepts of thought reform and "brainwashing", as well as the problem of "false positives" when abuse is alleged. S was surprised and pleased that the expert thought her smart enough to learn about these adult concepts. For the first time, she indicated she was willing to participate in a meeting with her father.

Despite mother's continued efforts to interfere, a one day visit between S and her father went forward when S was 13. The team agreed that the PAS expert should be present at father's house. The girl was thrilled by the interest shown in her by her father and step mother, whose desire to please her contrasted sharply with how her mother treated her. The expert had to intervene once when father and stepmother set reasonable limits and S exploded. When the reunification plan called for overnight visits to begin, S's court ordered individual therapist gave the girl her pager number, with instructions to call day or night if problems arose. S called to say that she didn't want to go back to her mother's. The therapist then had to set limits with S, reminding her that everyone, including S, had to adhere to the parameters of the reunification plan.

S encountered intense anger from her mother each time she returned home. One day, S took the risk of telling her mother that she wanted a relationship with her father. Mother slapped S and told the girl that she hated her and that the rest of mother's family hated S, too. In spite of mother's efforts to punish and intimidate S, the girl's relationship with her father and stepmother grew and the girl began to blossom. For the first time, S began receiving above average marks in school. She made friends and became involved with a boyfriend. Mother tried to persuade S to get pregnant so that mother could have the baby. When S was at her father's, mother maintained secret contact with her, encouraging S's impulsive, angry outbursts and telling her daughter to run away, which S did several times. As time went by, the reunification team and the court recognized that mother's treatment of S amounted to serious psychological abuse, interspersed with episodes of physical abuse.

Mother refused to participate in treatment or otherwise modify her behavior and the court eventually gave custody to the father. In defiance of court orders, mother continued her secret undermining of S's placement with the father until S had a mental breakdown and had to be hospitalized. Father and stepmother became so discouraged that they considered allowing S to resume living with her mother. The reunification team, backed by the judge, took the position that this was not an option. The team continued to provide coordinated services in support of S's placement with the father, and to offer outreach to the mother. By age 16, S was doing well on a consistent basis. S remained troubled by her mother's rejection and unwillingness to change but continued to hope that someday her mother would get help.

THE TARGET/ALIENATED PARENT IN PAS

Gender

Children are about twice as likely to form PAS type alignments with their mothers as they are with their fathers (3, 5, 6, 9). Similarly, fathers are more likely than mothers to become target parents, especially when abuse is falsely alleged (19-23). These and other gender differences were also discussed in Part I. Some fathers who become target or rejected parents in PAS give up and withdraw, contributing to the significant dropout rate of fathers after divorce. Others persist in their efforts to establish and maintain a meaningful post-divorce relationship with their children despite daunting obstacles. What motivates these men to persist in their efforts to father, despite rejection, calumny and protracted litigation ?

Struggle for Paternal Identity

Huntington studied fathers in a nonclinical sample of 184 couples who were cooperatively involved in divorce-specific activities at the Californa-based Center for Families in Transition (24). As fathers struggled with the issue of paternal identity after divorce, many found themselves closer to their children as part-time fathers than they were during the marriage when they were living with their children full-time. The emotional rewards of fathering gave some men new meaning to their lives after the loss, loneliness and feelings of failure engendered by the divorce. When fathers experienced a positive response from their children, they were more likely to pursue the relationship. Huntington also observed that fathers could be driven off by the child's rejection and refusal to visit. She referenced Gardner's 1985 article in which he introduced the term PAS.

Involuntary Child Absence Syndrome

According to Jacobs, a psychiatrist who edited a book on divorce and fatherhood, the stress reaction of some fathers to divorce is due to involuntary separation from their children (25). Such stress reactions in mothers are often given a positive connotation and attributed to "maternal instincts". Jacobs contends there is not nearly as much social support for fathers in a similar situation. He brought attention to the fact that fathers may have an equally strong need to nurture and parent, experiencing profound feelings of loss and frustration when reduced to a post-divorce relationship with their children which is minimal, diminished, or nonexistent. Working with fathers in a clinical setting, Jacobs found that the ability of these men to adjust to divorce was deeply impacted by their relationship with their children. Some fathers reported that they had been the primary parent during the marriage and that their children needed them in order to cope with a mother who was chaotic and disturbed.

The fathers Jacobs saw were convinced their children would suffer if the father-child bond was ruptured. They felt frustrated and sabotaged in their efforts to maintain the bond but refused to accept the idea that their children could develop well if the father-child relationship was severed. This was true for S's father in the case vignette above. Jacobs reported that the idea of being a "visitor "in their children's lives seemed second-rate and unacceptable to the fathers with whom he worked. Common adjustment reactions included anxiety, depression, hypervigilance and outrage, especially in response to denigration and expressions of hatred by their ex-wives.

Even if it was the father's decision to leave, he was often unprepared for the emotional and practical consequences where his children were concerned. Fathers of young children who were not guaranteed continued close contact felt particularly outraged and betrayed by the system, which was seen as unfair and biased toward mothers. Fantasies of self destruction, murder, and/or kidnapping were common, although usually not acted upon.

Circumstances of the Separation Which Increase Risk of Becoming a Target Parent

The likelihood that a mother or a father will become the target parent in an alienation scenario increases according to who is seen as responsible for the marital break-up (1, 5, 6, 9, 14). The risk increases when the parent seen as responsible for the break-up is discovered to have actually been unfaithful or becomes involved with a new partner immediately after the separation (1). Leaving the marriage precipitously may also incur in creased risk of becoming a target parent. The mother became the target parent in this example:

Mrs. E was a good mother but she was also guilt ridden and conflict avoidant. She tried to leave her husband several times but each time he persuaded her to return. When she left for the last time, she allowed the children, who were 3 and 5 years of age, tostay with their father on what mother believed to be a temporary basis. She was shocked at how the children treated her when she came to get them. They rejected her using profanity. Father filed for custody, accusing his wife of drug abuse, neglect and abandoning the children. He tricked Mrs. E. into not attending the custody hearing, telling her it had been put off. When mother failed to appear, the court granted father's motion for custody. It took several months for Mrs. E. to get the court to order a custody evaluation. By the time an evaluator was selected and the evaluation got underway, the children had been living with their father for a year. The evaluator observed that they were distant and somewhat fearful of their mother and recommended that the children remain with the father.

Contributions by the Target Parent to PAS

The relative contribution of the target parent to the PAS scenario varies widely, depending on the severity of the PAS, psychological issues of one or both parents, the target parent's capacity to parent, and other factors.

For intervention to be effective in PAS, it is important to carefully assess the relative contributions of each parent and to consider their relative capacities for a healthy parent/child relationship. Where the target/rejected parent is seriously disturbed, has abused the child or is seriously inadequate as a parent, the problem may be one of generic parent alienation and is not properly called Parental Alienation Syndrome.

In mild to moderate PAS, behavior of the target parent may contribute significantly, as in the case heard by Judge Tolbert which is further described below (26). The nine-year-old girl was refusing to visit her father and he claimed PAS by the mother. Based on the totality of the evidence, however, the court concluded that father's behavior contributed significantly to the child's refusal to visit. In particular, father was found to be excessively rigid and insensitive to his daughter's needs, seemingly an example of Johnston's observation that rejected parents are often inept and unempathic with their children (6, 10).

In severe PAS, the target parent may be relatively healthy and contribute minimally to the PAS, compared to the alienating parent. This is particularly likely to be the case with Divorce Related Malicious Parent Syndrome, where the alienating parent's anger, aggression, manipulation and deception tend to be driven by internal forces which far exceed external realities and contributions of the target parent (17, 18). The case vignette of Mr. and Mrs. C. in Part ( I ) demonstrated how a determined, unscrupulous father succeeded in wresting custody from a fit, custodial mother, who was the target parent.

According to Johnston's work with high conflict families, unresolved anger and continued narcissistic injury of either parent may contribute significantly to the child's rejection of one parent (6). Huntington found that in a nonclinical divorce sample, fathers sometimes engaged in controlling, provocative behavior in their efforts to reestablish a lost sense of control, especially if the divorce was not of their own choosing (24). Nicholas suggested that target parents may reinforce the PAS by assuming an ambivalent or inconsistent stance toward custody after years of litigation (27). Lund cited her experience with moderate PAS families in which the hated parent, usually the father, often exhibited a distant, rigid style which was seen by the child as authoritarian, especially in comparison to the preferred parent, who was overly indulgent and permissive (3). It is important not to overgeneralize, however, and to keep in mind that behavior of the aligned parent and child may influence and concretize the ambivalence reserve or indignation of the rejected parent.

Target Parents Who Are Falsely Accused

An accusation of child abuse, especially molestation, can quickly cut off an accused parent's access to his child, pending an investigation (28). Because sex abuse is often difficult if not impossible to disprove, the accused parent may spend months and even years trying without success to refute the charge. Clear resolution of such allegations may be impossible as a result of the accusing parent's actions, poor training and technique of the investigators, involvement of multiple agencies and lack of coordination between agencies and different branches of the judicial system (6).

Even if the charge is successfully refuted and the accused parent's rights are reinstated, the parent has lost valuable time with the child, damaging the parent-child relationship.

According to Patterson, additional repercussions for the falsely accused parent include damage to personal dignity, reputation in the community, and depletion of financial and other resources needed to defend the charge and to preempt the possibility of criminal action (29). An unproved accusation alone is sometimes enough to have an accused parent arrested and held in jail until a preliminary hearing and beyond. A parent who is criminally tried runs a significant risk of false conviction in the current legal climate. When sex abuse is alleged today, the presumption of innocence is often set aside with the justification that it is better to convict an innocent person than to allow a real child abuser to go free. Patterson's article references Gardner's book, The Parental Alienation Syndrome and the Differentiation Between Fabricated and Genuine Child Sex Abuse. Patterson concludes, "We can never serve a child's best interest by denying him or her the love and affection of a parent who has himself been victimized by a lie" (29; p. 941).

Benign and Positive Characteristics of Target Parents

Studies of target parents who are falsely accused of abuse report they tend to be less disturbed than their accusing counterparts (19, 21-23). Blush and Ross observed that falsely accused fathers tended to display passive or dependent features as compared with their more histrionic spouses (19, 21, 22). Sanders, an attorney who represents fathers in PAS type cases, indicated that she often found her clients to be emotionally and financially stable individuals who, prior to the separation, functioned as the primary parent for their children (30). When Dunne and Hedrick studied the effectiveness of various interventions in severe PAS, they found that better outcomes were achieved when the alienated parent was given custody (2). The alienating parents in the change of custody cases exhibited significant emotional disturbance in contrast to some of the target parents who were deemed fit and capable of establishing and maintaining a healthy parent/child bond.

Rogers reported similar findings in her review of cases in which certain alienating parents who made false allegations of abuse were found to suffer from Delusional Disorder, with the result that the father/target parents were eventually awarded custody in several in stances (31). The fact that target parents make good custodial parents in some cases is demonstrated in the vignette of S and her father, reported above. S's father was an unassuming man who worked in a clothing store. He was convinced that his daughter could not grow up well without him and was determined to play a positive role in her life. When he remarried, it was to a kind, capable woman who took a strong interest in S and who provided invaluable support when S was 13 and the father/daughter relationship was reestablished.

THIRD PARTIES WHO BECOME INVOLVED

Unholy Alliances and Tribal Warfare

In high conflict divorce, the social networks of the spouses can be come incorporated into the dispute scenario, helping to maintain, solidify or expand it, leading to "tribal warfare"(6). With the breakdown of the marriage, once private details of the couple's relationship often become the subject of lengthy conversations with sympathetic, potentially supportive others about what went wrong and who is at fault. Hearing primarily one side of the story, family, friends and professionals may lose their objectivity as they try to protect someone they care about or to bolster a parent's self esteem. Such support may be mixed, however, with what is experienced by the distressed parent as criticism, interference, obligations and demands which create stress above and beyond the divorce itself.

Johnston found that women were more likely after separation to depend economically on family members or kin. Women were also more likely to involve these "support people"in the parental disputes (6). Third parties entering the dispute initially were likely to do so on behalf of the mother. According to Johnston, the other side typically responded by as sembling a comparable array of allies. A stepwise progression of active and reactive coalition building was then likely to ensue.

New Partners

The advent of a new partner in divorce may escalate parental disputes over the child or precipitate new ones (6). A parent who feels threatened by an ex-spouse's new partner may initiate efforts to gain increased control of custody and visitation. Sometimes, new partners are the instigators and mobilizers of custody disputes, where previously there was little overt conflict between the parents. The new partner may be experiencing difficulties in the new marriage, feel a need to prove themselves, or be gratifying their own needs for domination and control. Alternatively, the new partner may bring a more objective viewpoint regarding the degree to which the child is being harmed by an emotional disturbance of the parent in the other household and provide a balancing influence.

Role of Mental Health Professionals

Mental health experts can become involved in contested custody/visitation disputes in a variety of roles: as evaluators, therapists, advocates, mediators, case managers, educators and/or consultants to parents or their attorneys. Mental health professionals may assist in identifying the needs of the child, assessing strengths and weaknesses of the parents, modifying the specific dynamics of parental conflict and advising the courts. In many jurisdictions, the courts are increasingly relying on the assistance and input of mental health professionals. This entails rising costs for divorcing parents who must pay for these services. Some argue that mental health services which help to reduce the often escalating cycle of action and reaction between the parents saves them money in the long run by reducing litigation costs. On the other hand, mental health services may be protracted and ineffective in high conflict cases. Sometimes they actually cause damage to the parties and to family relationships.

Potentially Harmful Influence of Mental Health Professionals

Written and verbal statements by custody evaluators can have a negative impact on disputing parents, especially when the situation is explained in terms of what is wrong with the parents (6). Parents are particularly vulnerable during the upheaval of the separation. Comments by mental health professionals in this context, especially when publicized, can escalate parents' needs to vindicate and defend themselves from further exposure and humiliation.

Lund pointed out that therapists, especially individual child therapists, can unwittingly become part of the system maintaining PAS (3). This is more likely to occur when the therapist takes statements by the aligned parent and child at face value, lacks knowledge about PAS and avoids contact with the target parent.

Campbell (32) discussed the pitfalls of triangulated relationships in doing therapy with children of divorce, citing Gardner's first book on PAS (33) in the opening paragraph. One of the problems for therapists seeing children of divorce is that the parent who selects the child's therapist, who brings the child for therapy and who arranges for payment is in a position to influence the therapist regarding the therapist's role, the goals of treat ment, and who participates. Therapists who are provided with incomplete, selective data are at risk for reinforcing and endorsing the idea that the child needs to be "saved" from the alienated parent. A variation of the victim-villain-rescuer triangle may then develop. Citing well known family therapist Murray Bowen, Campbell observed, "When clients and therapists organize their relationship around the reciprocity of victim and savior, the identity of each demands that the other persist in their respective role " (34; p. 479). When abuse is alleged, advocate therapists may become so overinvolved as to exhibit what amounts to a shared paranoid disorder with the aligned parent and child (35).

Campbell observed that professionals can become slowly compromised by the "us versus them "mentality in the context of adversarial family relationships and legal proceedings (32). As discussed in the section to follow, an advocate therapist for an aligned parent and child may inappropriately use the therapy sessions to "validate "allegations of abuse against the target parent, rather than helping the child adjust to the divorce and maintain affection for both parents. The individual therapist for an alienating parent may agree to recommend to the court that the client have custody, without meeting the other parent. Target parents may also recruit advocate therapists to their side, as demonstrated by the father in Judge Tolbert's case (26), which is presented below. Mental health professionals who make custody recommendations without interviewing both parents may be in violation of ethical standards. Where professionals compromise themselves in high conflict cases, valuable information about parental dynamics can often be gleaned from analyzing the process by which this occurred.

Influence of Therapist Attitudes

The fundamental beliefs of many therapists about the etiology of psychological problems and what constitutes appropriate treatment can make the therapist an unwitting reinforcer of alienation. Psychotherapy is a potent form of social influence. Campbell conducted a study which revealed that the majority of therapists. make significantly Read More ..gative than positive inferences about significant others in their client's lives (34). In addition, therapists frequently assume that the client's psychological distress has its origins in an interpersonal environment which is "disrespectful psychologically avoidant, unempathic and punitive". These assumptions can substantially influence the course of treatment and the client's view of their situation. Children of divorce may feel overwhelmed by the chaos and hostility of their parents' conflicts. They may also feel a sense of betrayal when a parent moves out and the parents are focusing Read More .. their conflicts with each other than on their parental responsibilities (32).

Child therapists who are predisposed to making negative inferences about significant others in the child's life may inadvertently reinforce a child's sense of anger and blame toward a target parent, sometimes in very subtle, pernicious ways. Where the therapist's own view of the target/alienated parent is negative, even if only to mild degree, the therapist's view is likely to adversely influence the child. This provides fertile ground for the development and reinforcement of PAS. A detailed example of such a process is presented in The Real World of Child Interrogations which contains an analysis of multiple child therapy sessions in a contested custody case (36). Transcripts of the sessions illustrate the process by which the therapist helped teach the child to make abuse allegations and reinforced the child's expressions of hatred toward the target parent - in this case the father.

When abuse is alleged, anyone in a position of authority can act as a "validator," including therapists, police, child protection workers, and medical personnel (37). Validators are professionals who, when presented with allegations of abuse, assume that abuse occurred. They see their role as validating the alleged abuse rather than conducting an objective investigation. Validators are relatively easy to find, especially when sought out by a parent seeking to strengthen their position in legal proceedings.

Validator interviews of the child tend to promote the child's voicing of an abuse scenario, whether or not abuse occurred.

Real World of Child Interrogations

Once the issue of molestation is raised, the child is often subjected to repeated interviews and evaluations, sometimes more than 20, according to a family law judge in California (28). An analysis of 150 tape-recorded abuse interviews with children identified specific adult interviewer behaviors which influence children to alter accounts and to say things that will satisfy or please the interviewer (36). Most adults are unaware of how their ideas and expectations teach children to conform their accounts to the expectations of the adult interviewer. When the child is brought by a parent for an abuse interview, the parent's report of what occurred tends to shape the interviewer's ideas about what occurred and the questions which are asked. These interviewer expectations are communicated to the child through the adult's reactions, leading questions and other suggestive techniques (e.g., drawings or "anatomical dolls"). Such effects occur even among professionals trained not to use suggestive methods.

Suggestibility of Children's Recollections

There has been a growing body of research in recent years which shows the potential for interviews to teach children what adults expect to hear. Ceci and Bruck conducted a comprehensive historical review and synthesis of this research in an article on the suggestibility of witnesses (38). These authors cited Gardner as raising important questions about the ability of powerful authority figures to coach children and about children's ability to differentiate fact from fantasy. Ceci and Bruck's review resulted in several important scientific findings:

1) There appear to be significant age differences in suggestibility, with preschool children more vulnerable to suggestion than either school-age children or adults.

2) Children can be led to make false or inaccurate reports about very crucial, personally experienced, central events.

3) Children sometimes lie when the motivational structure is tilted toward lying.

4) The previous points notwithstanding, children, including pre schoolers, are capable of recalling much that is forensically relevant.

Ceci and Bruck concluded that in order to know the reliability of a child's report, the conditions surrounding the report need to be carefully evaluated, including prior access to the child by an adult motivated to distort the child's recollections. Distortions frequently occur as a result of relentless and potent suggestions by adults, sometimes to the point of outright coaching.

Memory Research and its Forensic Implications

Many people subscribe to the incorrect belief that memory is somehow fixed and not malleable. Loftus and her husband surveyed 169 people from a variety of socioeconomic groups (39). The majority of respondents endorsed the belief that everything we learn is permanently stored in the mind and that consciously inaccessible details can be recovered with the use of special techniques such as hypnosis. Psychology graduate students were particularly prone to endorse this view, although it is disproved by three decades of research. It turns out that memory can be altered in a myriad of ways.

The implications for law enforcement and the courts are staggering since eyewitness testimony is heavily relied upon in these set tings. The American Psychological Association sought to address these problems where children are concerned, publishing a compilation of articles by psychology's leading authorities on memory entitled The Suggestibility of Children's Recollections: Implications for Eyewitness Testimony (40). Ceci and Loftus were among the contributors.

Parents as Interviewers

Parents who are preoccupied with suspicions of abuse by the other parent often question their children repeatedly. Some false allegations of abuse in divorce begin with a parent questioning the child after visitation about a rash, a bruise, or bathing at the other parent's house. Everson described the case of a six-year-old-boy who produced more and more elaborate accounts of abuse in response to the attention and support he received from his mother as they discussed "his memories" of abuse each night at bedtime (41). Initially, the child provided a consistent, plausible account of a teenage baby-sitter fondling his genitals and anus. The baby-sitter confessed to this. Over the course of several months, however, the child's description of what occurred became more ekborate, bizarre, implausible, and finally impossible. According to Everson, the child may have become confused about the source of his more fantastic "memories" which probably grew out of the conversations with his mother. This is sometimes referred as "source amnesia". Everson referenced Gardner's work relating to the assessment of child sexual abuse.

When Cults Have a Role in Parental Alienation

In extreme cases, a divorced parent determined to deprive the other parent of a relationship with the child will join a cult for the powerful help the group can provide in alienating the child from the other parent. In an effort to recruit and control members, cults have perfected the art of parental alienation. Cults are sometimes involved in parental child abductions. Attorney Ford Greene, who specializes in litigation against cults, contributed the following family law case (42).

Mr. Y was wounded and angry when the mother of his only son decided to end their common law marriage. Mrs. Y was eager to mediate the dissolution and offered to stipulate to joint legal custody with reasonable visitation to the father. Mr. Y refused and took Mrs. Y to court, where the judge ordered the custody/visitation plan first suggested by the mother. Mr. Y became involved with a quasi-religious cult. He used his visitation time to involve his 10-year-old son in the group's activities. Under the auspices of the group, the boy was regularly hooked up to a biofeedback device for the purpose of training him to become "emotionally disconnected" when thinking about or interacting with his mother. The child's mental state and behavior gradually deteriorated. One day, the boy did not return to his mother's home after school. Instead, he rode his bike ten miles from school to the ferry, crossing the bay and riding through a bad part of town to reach the group's headquarters where his father was waiting for him. Mother turned to the court for assistance in getting her son back and protecting him from the father and the group. The group tried strenuously to prevent the court from intervening, invoking the special protections the law provides for religious beliefs. Greene, who was representing the mother, focused on specific group practices which were physically or psychologically detrimental to the child's best interests. He stayed away from the legitimacy of the group's religious doctrines. After hearing the evidence, the court found that the group's influence on the child was mentally and emotionally detrimental. Mother was awarded sole legal and physical custody.

People tend to think of cults as large, well organized groups. According to Singer and Lalich, however, cultic social organization can also be found in very small groups, such as the Symbionese Liberation Army (SLA) which abducted Patricia Hearst (43). Cults can be organized around different ideological themes such as prosperity, health, psychotherapy, UFOs, or religion.

Regardless of size or thematic focus, cults share certain social structures in common. The group is built around a charismatic leader who controls the members directly, or indirectly with the help of loyal followers. Cults routinely employ deception in recruiting, often using elaborate, cleverly conceived fronts to conceal the true nature of their activities. New members are taken through a progressive process of thought reform, sometimes referred to as "brainwashing". Compliance is obtained in small steps which isolate inductees from the influence of non-members and which foster dependence on the group. The process discourages criticism of the group's ideas and encourages inductees to replace "old" ideas and relationships with the group's ideology, which is portrayed as "new" and more advanced. Recruits are encouraged to reject the past and to drastically reinterpret their life history. These tactics destabilize the inductee's sense of self and increase motivation to serve the group and its leader. When the recruit's indoctrination is complete, he or she can then be deployed as an agent of the organization, to help expand the group's financial resources, power, and influence.

Almost anyone can be drawn into a cult under the right set of circumstances (43). People are most vulnerable to recruitment when they are depressed and between affiliations. Almost by definition, parents of divorce are "between affiliations". To varying degrees, they are also likely to experience depression at some point in the divorce process. Religious cults may appeal to divorce parents who are seeking validation of their blamelessness and moral superiority in the proceedings. Pastors and other church members in fundamentalist religious cults may openly denigrate the target / alienated parent to the children, claiming the authority of their holy book in referring to the target parent as an "adulterer", "harlot" or "whore".

In a presentation at a recent forensic conference, Bower (44) pointed out similarities between the mechanisms by which cult leaders control their followers and the tactics of alienating parents who form "unholy alliances" with their children. Similar comparisons appear in Children Held Hostage (1). This study of 700 divorce families, was reviewed in Part I. Clawar and Rivlin anchored their research in 30 years of literature on the psychology of social influence, including indoctrination techniques variously referred to as brainwashing, mind control, thought reform, modeling, reeducation and coercive persuasion. Bower likened the alienating parent to the leader of a one-on-one or small group cult, pointing out that children's dependence on parents makes them vulnerable to this source of influence. The aligned parent and child, along with other supporters of the alienating parent's views, come to share, a closed, impermeable belief system, similar to the fixed ideology of an organized cult.

In normal circumstances, the power differential in parent / child relationships helps parents to instill a sense of conscience and moral values in their children. As children grow, the love they experienced from their parents in early years becomes a model for treating others with courtesy and considering other people's feelings. In more severe PAS however, the child's social and moral development are co-opted to varying degrees by the alienating parent's agenda. In extreme cases, children growing up in the custody of an alienating parent become "corrupted," in the sense defined by Garbarino et al. They are encouraged to use deceit, manipulation and aggression in the service of the PAS agenda. The SLA succeeded in "corrupting" Patricia Hearst for a time: after she was subjected to isolation, indoctrination, terror and intimidation, she was induced to participate in a bank robbery, a violation not only of the law itself, but of her previous moral values. Once separated from the SLA, she was able to resume prosocial values.

In extreme cases of cult indoctrination, members are trained to commit suicide rather than have contact with "evil", "dangerous" outsiders. In a parallel situation, severe PAS sometimes involves direct or indirect encouragement by the alienating parent for the child to threaten suicide or homicide if forced to have contact with the alienated parent. Johnston encountered a case in which a 10-year-old boy hung himself when the court ordered that he be placed in the custody of his alienated father (10). Two cases of attempted homicide by the child were reported in Part I (4, 45). Both boys were in folie a deux relationships with their disturbed mothers after the parents divorced.

One boy tried to poison his father (4), the other tried to burn his father's house down (45). Careful evaluation and case management are required when there is reason to suspect that the child may be a danger to self or others. Part III, devoted to interventions in PAS, will include the case vignette of two sisters who threatened suicide and homicide when told they would be court ordered to see their father. Father had been the custodial parent per order of the family court. Mother succeeded in alienating them and got custody through the dependency court, by involving the children in false allegations of abuse. The girls' threats were taken seriously and the family court ordered hospitalization at a facility willing to deal with the possibility of PAS. In the safety of a contained, closely monitored, therapeutic setting, the girls were successfully returned to father's custody.

PAS IN THE LEGAL ARENA

Legal Recognition of PAS

An increasing number of attorneys are publishing articles which recognize and seek to address the problem of parental alienation, variously using the term Parental Alienation Syndrome in the title, in the text or in the bibliography (30, 46, 47, 49, 50, 54, 55). California attorney Patrick Clancy posts his Points and Authorities for the Admissibility of PAS Testimony on his web site. An article by Wood opposes legal recognition of PAS (56). Family law judges have been producing a growing body of opinions which discuss PAS by name or include findings of parental alienation without giving it a special label (26, 46, 47, 54-57). A 1997 issue of The Judges' Journal included an article on managing visitation interference by Turkat (57), who has been referencing Gardner's work on PAS for several years. Judge Vernon Nakahara in Alameda County, California, spoke with author Deirdre Rand about his opinion that judges need to be made aware of Gardner's work on PAS. Judge Nakahara also shared his views on the role of the family law court in dealing with PAS and other high conflict cases.

A Florida attorney was the first to write about PAS after Gardner introduced the term in 1985. Palmer's article, published in 1988, described PAS as a strategy some parents were using to avoid their obligation to share parenting responsibility under Florida law (46). She discussed two legal cases, including Schutz v. Schutz in which the judge opined: "The Court has no doubt that the cause of the blind, brainwashed, bigoted, belligerence of the children toward the father grew from the soil nurtured, watered and tilled by the mother. The Court is thoroughly convinced that the mother breached every duty she owed as the custodial parent to the noncustodial parent of instilling love, respect and feeling in the children for their father. Worse, she slowly dripped poison into the minds of these children, maybe even beyond the power of this Court to find the antidote" (46; pp. 361-362). Palmer foresaw the need for early evaluation and intervention in cases of PAS and those with that potential, in order to prevent the development of completed, intractablealienation. She recommended the use of judicial sanctions to hold alienating parents accountable and to provide incentives for changing their behavior.

In 1991, a Canadian law journal published an article by Goldwater which strongly supports legal recognition of PAS (47). According to Goldwater, Gardner's 1989 book on family evaluation in child custody (48) "is certainly required reading for the family practitioner and should be considered the source document on the phenomenon of parental alienation syndrome...Indeed, there is a moral failure in smugly asserting that children have 'rights' without taking into account their evident lack of autonomy and their material and psychological vulnerability to control and manipulation" (47; pp. 121-122). Although the title is in French, most of the text is in English. Canadian law and case citations are discussed.

In 1993, two articles were written by attorneys; one from New Hampshire (49) and one from South Carolina (30). These articles took a practical approach to the special difficulties PAS cases pose to family lawyers, mental health professionals and to the courts. Ward and Harvey are a psychologist and an attorney, respectively (49). Their article distinguishes between "typical" divorce and "alienation". Alienation cases are distinguished by the nature and extent of a parent's willingness to involve the children.

According to Ward and Harvey, alienation family systems require their own specific interventions, a point Gardner continues to emphasize. They build on Gardner's concepts about PAS and synthesize them with Johnston's work on the divorce impasse and high conflict families.

Sanders discussed PAS along with bad-faith relocation and fabricated sex-abuse allegations (30). She referred to Parental Alienation Syndrome as a disorder named by Gardner. She thought that mental health professionals and family law judges were becoming increasingly aware of the harmful process of parental alienation, regardless of the terminology used. Support for this contention can be found by perusing the programs of family law conferences in recent years. Since at least 1994, conferences of the Association of Family and Conciliation Courts have featured presentations on parental alienation. Gardner's concepts regarding PAS are often referred to and his books on PAS are listed in the bibliographies of hand outs (50-53). Gardner himself presents at major conferences, for example, the Children's Rights Council Conference in Washington, D.C., which is attended by mediators, psychologists, and attorneys, who receive continuing education credits. Continuing education credits were also available to professionals attending the 1997 conference of the American College of Forensic Psychology, which included a presentation on the similarities between PAS and cults, discussed above (44).

Practicing psychology and law in Wisconsin, Waldron and Joanis put forth the view that PAS was readily accepted not because it was a "discovery" but because Gardner succeeded in conceptualizing and describing a familiar, complex, perplexing problem of divorce families which can have tragic consequences and is resistant to change (54). The article contains a number of case citations and a discussion of Karen "PP" v. Clyde "00. " This case involved a mother who sought to have father's visitation supervised because of alleged sexual abuse. Opinions of the ex-parts involved differed as to whether or not the alleged abuse occurred. According to Waldron and Harvey, this case is often inaccurately depicted as showing the "dangers" of PAS. The court's opinion is often criticized for quoting Gardner's work at length (56), as if this was the sole basis for the court's findings. However, when Waldron and Joanis examined the text of the court's rulings, they found that the court's decisions were based on the evidence presented, not on Gardner's theories. Their article is distinguished for its use of the social influence model outlined by Clawar and Rivlin and its reference to their research.

In Florida, Walsh and Bone practice law and psychotherapy, respectively (55). Their article on PAS, published in June, 1997, appears to be the most recent paper on the subject by attorneys. According to these authors, courts in their state are not at all hesitant about making a decision regarding PAS where the challenging parent can present credible proof and evidence of incidents in which the other parent has been practicing alienation and visitation interference. Four Florida case citations are provided in support of this assertion. These authors highlight the need to assess and understand parental deceit and manipulation, referencing Turkat's work on child visitation interference (57). "Make no mistake about it. Individuals with either PAS or a related malicious syndrome will and do lie! They are convincing witnesses, and their manipulative skills may influence others to follow suit" (55; p. 94).

One of the presentations (50) and three of the articles (49, 54, 55) mentioned above were coauthored by an attorney and a mental health professional. This may represent a trend of increasing collaboration between legal and mental health professionals who provide divorce related services. Recently, psychologist Sharon Montgomery from New Jersey discussed PAS during a panel presentation with two attorneys (58). California psychologist Anita Lampel (7, 8) began editing The Family LAP in 1996. The first two issues of this newsletter for attorneys and others interested in family law and psychology contained columns on children of divorce who are alienated or who have rejected one parent (59).

Wood argued against the admission of PAS testimony in the Loyola of Los Angeles Law Review (56). She was outraged over the outcome of a divorce/custody dispute in which Dr. Gardner testified. Father was awarded custody after the court found that mother's allegations of abuse against him were without merit. Wood attacked Gardner personally as well as arguing against his ideas. She warned that an erroneous decision based on PAS testimony could result in a child being placed with an abusive parent and leave the child with "no one to tell." Wood failed to point out that allowing a child to remain in the custody of a parent engaged in serious alienating behavior, if such is the case, puts the child at risk for significant psychological maltreatment, as in the case vignette of S, above.

Judge Tolbert on PAS

An extensive opinion by Judge Tolbert, published in the New York Law-Journal in 1990, demonstrates the court's ability to match specific evidence with expert testimony on PAS (26). Judge Tolbert heard testimony on PAS by two experts, including Dr. Gardner who was originally involved as the court-appointed custody evaluator. The child in the dispute was a 9-year-old girl who was refusing visitation with her father. Father retained his own psychological expert who testified that the child's refusal to visit was the result of severe PAS on the part of the mother. Father's expert recommended that the father be awarded custody, although he did not interview the mother. Dr. Gardner testified that mother's contribution to the child's refusal to visit constituted PAS in the mild to moderate range and that the mother / daughter bond was basically healthy. Based on the evidence presented, including the testimony of other witnesses, Judge Tolbert concluded that the father's own behavior was a significant contributing factor to the child's refusal to visit. Father had been unreasonable and provocative toward the child's mother and his excessive rigidity made him insensitive to his daughter's needs. Judge Tolbert found that the facts of the case supported Dr. Gardner's testimony and that the mother should retain custody. He ordered the parents to participate in family therapy aimed at addressing the problems each of them brought to the situation. Judge Tolbert opined that PAS is not so much an emerging area of expertise as a phrase pioneered by Dr. Gardner, similar to the view expressed by Sanders (30) and Waldron and Joanis (54).

Judge Nakahara on PAS and the Role of the Court in Family Law

Judge Vernon Nakahara in Alameda County, California, served on the family law bench for a year after many years as a criminal court judge [Judge Nakahara provided the material in this section by personal communication to author Deirdre Rand in 1997]. When the assignment expired, he elected to continue as the judge for a particularly severe case of PAS. It had taken him several months to grasp the complexities of the case and he was concerned that the case would be set back if a new judge had go through the process all over again.

Judge Nakahara learned about Gardner's concept of PAS from the testimony of the court appointed reunification therapist for the child in a severe PAS case. The idea made sense to him and helped to explain some of the divorce family problems he was seeing. Upon reading the above quote from the judge in Shutz v. Shutz, Judge Nakahara indicated that the description was consistent with his experience. He observed that the alienating parent in more severe PAS usually had significant psychological problems. False allegations of abuse were also more likely to be part of the equation. According to Judge Nakahara, varying degrees of PAS were evident in most of the family law cases he heard, similar to what Gardner (33) and Johnston (9) report. He cautions family law judges to be aware that in addition to the child, professionals upon whom the court relies may also be "brainwashed" by the alienating parent. This includes attorneys, family court services and private counselors. The opinions of various professionals who become involved should not be accepted as authoritative simply because individuals designated as professionals are making them. The opinions of professionals need to be tested and critically evaluated by the court.

Attorneys and parents also need to be held accountable. During his term on the family law bench, Judge Nakahara did not allow the common family law practice of the court relying on attorneys' representations as to what their client / parents and other witnesses would testify to if called. Similar to criminal cases, he insisted on live testimony so he could test the credibility of witnesses himself. At first, family lawyers in his courtroom were surprised that he expected them to show substantial proof in support of their claims and of the client's position.

They were also surprised by his readiness to impose sanctions. Attorneys quickly learned that they needed to be more careful about their representations in Judge Nakahara's court room and that they would be required to back up their claims.

According to Judge Nakahara, holding parents accountable builds success. Relieving a parent of sanctions builds failure and increases the likelihood that unacceptable behavior will recur. Failure to impose sanctions when sanctions are called for reinforces parents' disregard for court orders and their belief that they can do as they please. When Judge Nakahara threatened parents with sanctions, he gave them choices. One alienating mother failed to take her child to 12 of the 15 court ordered therapy appointments. Judge Nakahara gave her the following choices: 1) take the child for the sessions; 2) spend a day in jail for each session missed; or 3) if mother continued her refusal to cooperate, custody would be switched to the father. At this point the mother decided to start bringing the child for therapy. In another case, a parent with a pattern of visitation interference was frequently tardy for visitation exchanges. Judge Nakahara required the late parent to pay $ 1 for each minute past the appointed time. He also applied sanctions for such issues as refusal to produce income and expense information, failure to participate in court ordered alcohol treatment and failure to attend the requisite number of anger management classes.

When lesser sanctions failed to produce results, Judge Nakahara did not hesitate to order that a noncompliant parent be taken into custody. The first time he did this on the family law bench, it created a "shock wave" throughout the county legal system - it had been five years since a family law judge in the county had imposed this level of sanction. Experience taught Judge Nakahara that five days in jail is the optimum period of time to make a significant impression on a parent who persists in violating and resisting court orders.

Role of Attorneys

In the advocacy role, attorneys customarily allow the client to define the goal of the attorney's efforts, zealously advancing the client's position. In PAS cases, this approach may not be in the client's or the child's best interest, especially when the attorney is representing an alienating parent or a fully alienated child. Waldron and Joanis observed, " The lawyer for the AP [Alienating Parent] has a difficult role. The AP has collected evidence and invested time and energy in his or her role and has rectitude and certainty on his or her side, or so he or she believes. The AP wants badly for the lawyer...to agree with him or her. The lawyer has been hired, however, for his or her knowledge and judgment " (54; p. 130). Waldron and Joanis recommend that attorneys who represent such parents should advise their clients to terminate the behavior, in the best interest of their case. FurtherRead More .." When an attorney...has been appointed to represent the interests of the child...this attorney needs to avoid being swept up in the seductive process of PAS and remain neutral, with a focus on concrete evidence" (54; pp. 130-131). Sanders, who primarily represents rejected / alienated parents, recommends that before taking action, the attorney should determine whether the client is the problem, interviewing collaterals, obtaining a polygraph, or asking the client to undergo an independent psychological evaluation if necessary (30). Similarly, Ward and Harvey assert, " It is incumbent on the attorney to sufficiently explore the client's motivation and the reality basis of the client's beliefs before litigation is undertaken " (49; p. 35).

Psychological Experts in Divorce

According to Sanders, attorneys representing target parents in PAS cases must retain a strong psychological expert (30). For judges unfamiliar with PAS, the expert's role in educating the court is essential. Otherwise, the judge will most likely make orders which are not strong enough to remedy the problem. This is especially true for judges who are unfamiliar with family law cases and do not have a particular interest in that area. In some jurisdictions in California, including Alameda County where Judge Nakahara presides, judges are assigned to the family law bench for a one year. Certain states, such as Colorado, do not have a family court system. Judges in some districts can be assigned to family law cases that they do not want, and their motivation to read custody reports and be alert to alienation issues may be minimal (50).

Sanders reported that when an alienated father is seeking custody, he should have a psychological expert who is prepared to give a strong opinion on the severity of the problem and the improbability that individual therapy for the mother or a restraining order against alienating behavior will be enough to remedy the situation (30). It may be crucial to persuade the court that the child's relationship with the target parent cannot be re paired unless custody is removed from the alienating parent.

Waldron and Joanis identified the danger in PAS cases of the professionals who become involved becoming as split and contentious as the parents (54). When possible, they recommend that mental health professionals who become involved work collaboratively with each other and with the attorneys. Depending on the circumstances, it may be possible for an expert who enters the case on the side of one parent or the other to eventually become part of the case management team, especially if the court orders it, as in the case vignette of S, above.

Ackerman and Kane included a section on PAS in the 1991 supplement to their reference work on psychological experts in divorce and other civil actions (59). In a subsequent edition, information about Gardner's work on PAS was included in the body of the text (60). Attorneys involved in difficult family law cases must be able to critically assess the qualifications and work of mental health professionals. Family lawyers may be expected to cooperate and participate in the selection of a custody evaluator, case manager, or therapist for the child. Attorneys must also be prepared to probe the findings of mental health professionals and to cross-examine them.

Family Law Versus Dependency Court

Decisions by the court in family law are based on "best interest of the child," usually interpreted to mean that children are better served when the court makes orders which enable them to maintain a positive relationship with both parents. There is also support for the rights of the parents to have a relationship with their children. The dependency system is designed to find abuse and to protect children from parents thought to be abusing them. In dependency or juvenile court proceedings, the state acts to protect children who are deemed to be at risk of being harmed, with the court assuming the role of the custodial parent. The juvenile court has the power to order a child taken into protective custody prior to a hearing and can terminate parental rights. The juvenile court may take jurisdiction in a family law matter even when the allegations of abuse have been previously litigated in family law court and found to be invalid (61).

Some alienating parents succeed in mobilizing the child protection system (CPS) to help sever the target parent's contact with the child. This is what happened in the case vignette of Mr. and Mrs. C in Part I. The case was unusual for the fact that the alienating parent was a father. He obtained custody of his daughter in dependency court after failing to accomplish this goal during several years of family law proceedings. Most of the CPS workers who became involved rejected the idea of PAS, despite in formation from mental health professionals who had been recognized by the family law court or who had provided therapy to the girl and her mother. As this case demonstrates, CPS workers tend to be less familiar with the dynamics of high conflict divorce. They are less likely to consider such potentially contaminating factors as parental influence and repeated abuse interviews of the child by police, social workers, therapists, and others. In severe alienation, the alienating parent may move from one county or state to another, beginning a new round of investigation into the abuse allegations and seeking better support for terminating the target parent's contact with the child (52).

On the other hand, when CPS workers are receptive to the experts' diagnosis of PAS, CPS can help contain the alienating parent's behavior, as the following case illustrates.

Mr. H successfully alienated his 11-year-old son and 9-year-old daughter from their mother after learning of mother's desire to divorce. Prior to the separation, mother was the primary parent. A court ordered custody evaluation found her parenting ability to be average. Father and the children used mother's new significant other as a rationale to vilify her.

The siblings played off each other and supported each other's extreme and hysterical protestations of hatred against their mother. The children did not see their mother for a year. A Special Master was appointed who referred the family to a PAS expert for treatment. When the therapist informed the children of his intention to hold a conjoint counseling interview with them and their mother, the 11-year-old boy became physically ill. Despite the therapist's efforts to persuade father and children of the need for a meeting with the mother, they refused to participate. The Special Master ordered such a meeting and still father refused.

Finally, the PAS therapist contacted CPS and made a suspected child abuse report against the father for severe psychological abuse in conjunction with his alienating behavior. The social worker who talked to the father and children was supportive of the therapist's concerns and agreed to back him up. The therapist, too, met with the father. He told Mr. H his reasons for the suspected abuse report and informed him that CPS was prepared to intervene, possibly removing the children from his home, if he did not turn the PAS situation around within a few months. The therapist gave Mr. H Gardner's book on PAS to read and told him that he was acting in this manner with his children. When father tried to tell the children that they had to rebuild their relationship with their mother and begin visitation, the children became angry and combative. Father became frightened that he would have problems with CPS and might be dragged into family law court by the children's mother. Mr. H worked harder to turn the situation around. The CPS worker met with the children twice and continued to advise father of the gravity of CPS' concerns. Soon, the children were able to begin visitation with their mother every other weekend. After several months, visitation was increased to every other week with each parent. Father needed a great deal of support to remedy the situation and mother was in a position to help him. As a result, a moderate degree of coparenting became possible and CPS formally closed the case. At two year follow-up, the children were doing well with both parents, a "win-win" solution for everyone involved, due to the willingness of CPS to work with the PAS expert.

Criminal Proceedings Against a Falsely Accused Parent

A parent falsely accused of some criminal act in the context of a divorce/custody dispute is at risk for prosecution. Like the juvenile court, criminal courts are unlikely to be familiar with the dynamics of high-conflict divorce and PAS (29). In the following case vignette, the accused father was an officer in the military. Testimony on PAS by the defense psychological expert provided the judge and jury with some alternative explanations as to the reasons the children accused their stepfather of abuse.

Mr. B was court-martialed after being accused, in the context of divorce, of molesting his wife's 10- and 14-year-old daughters from another marriage. Mrs. B and the girls accused Mr. B after Mrs. B learned of her husband's second infidelity. A similar sequence took place two years earlier when Mrs. B discovered an infidelity. At that time, Mrs. B moved out temporarily and called authorities to report that Mr. B was sexually abusing her daughters. On that occasion, Mrs. B decided to move back in with her husband and withdrew the accusations.

The military defense attorney retained a psychologist with expertise in PAS to testify at the criminal trial. The judge ordered the girls and their mother to participate in an evaluation by the defense expert. The military flew the family across the country several days before the trial in order for this to occur. A female pediatrician in the military, who planned to testify for the prosecution, accompanied the girls and their mother to the defense psychologist's office. The pediatrician remained in the waiting room and conversed with the family members and the psychologist at different break points in the evaluation. The PAS expert ascertained that the girls were very attached to Mr. B prior to their mother filing for divorce.

The biological father ran off when the girls were very young and Mr. B raised them as his own. The molestation accounts given by the girls contained numerous inconsistencies and were not supported by medical evidence. Documents reviewed by the PAS expert also indicated that the children's account had become more and more exaggerated with time. In the course of the day at the defense expert's once, the number of incidents reported by the girls went from the six counts with which Mr. B was originally charged, to more than forty-five.

The court permitted Mr. B's expert to testify in regard to PAS with false allegations of abuse. The jury found that the facts of the case conformed to the defense expert's opinion, and the stepfather was found not guilty.

Points and Authorities for the Admissibility of PAS Testimony

California attorney Patrick Clancy posts his Points and Authorities for the Admissibility of PAS Testimony on his web site, http://www.accused.com. The brief argues that testimony regarding Parental Alienation Syndrome is necessary to establish a child's motive to fabricate, and that such a motive is not readily apparent to the layman. Case law supports the right of a parent/defendant who is charged with molesting his child but maintains his innocence to establish motives other than his misconduct for the child to hate, fear or falsely accuse him. The prosecution in a murder trial, People v. Phillips, was allowed to introduce evidence of Munchausen Syndrome by Proxy (MSP) as a possible motive for the mother in killing her child. According to Clancy the defendant/parent accused of abuse has a stronger case for the admissibility of PAS testimony than the prosecution's case for the admissibility of testimony in regards to MSP. The family court in Re Anne P. gave tacit recognition of PAS, finding that the allegations of abuse abuse the father were false and that the mother was responsible for the allegations, by virtue of her mental disturbance and her unrelenting struggle with the father. Within the year, mother contacted CPS and eventually a dependency petition was filed. In this case, the juvenile court upheld the findings of the family court, attributing the allegations to mother's "pure out and out hatred....antagonism" toward the father.

List of PAS Case Citations in Dr. Gardner's Web Site

A list of case citations involving PAS can be obtained from Dr. Gardner's web site.

FORENSIC EVALUATION AND PAS

Custody Evaluators on PAS

Kopetski reported on 84 serious PAS cases from a sample of 413 court ordered custody evaluations in Colorado (63). The assessments were conducted by the Family and Children's Evaluation Team (FCET), of which Kopetski was a member. Their protocol included structured interviews of each parent, obtaining developmental histories for the children, observations of parent-child interaction and individual evaluation of the child. Beginning in 1988, formal psychological testing of the parents was performed for all cases in which there were allegations of abuse, neglect, or a parent was seeking to restrict or exclude the other parent's contact with the child. Prior to learning of Gardner's work, the team independently came to very similar conclusions. Kopetski characterizes PAS as a form of psychosocial pathology in which a parent psychologically exploits the child and appropriates social systems in order to achieve alienation. The team's formulations reflect a social influence model and Clawar and Rivlin's work is referenced. Bowlby's attachment theories were found to be the most useful for understanding PAS. The team concurred with Bowlby's observation that "strong" or "intense" parent-child attachments are not necessarily healthy ones.

In 18 percent of FCET's PAS cases, the alienating parent was successful in preventing the children from having a relationship with the target parent in spite of recommendations against alienation. "One of the most surprising and discouraging findings in this survey was that in 15 families in which a parent was successfully alienated, the alienation was supported by a therapist on the basis that the child should not be separated from a 'symbiotic relationship' [with the alienating parent], even though the 'symbiosis' proceeded far beyond the time when such a parent-child relationship could even remotely be considered. It was as though the therapists had joined the delusion that the child could not survive if separated from the symbiotic parent" (63; p. 13). Unlike Johnston who has been supporting the idea of allowing children to remain in such relationships (9, 10), Kopetski and her colleagues recommend placing the child with the parent who has the most potential for promoting the child's psychological and social development.

Nicholas, a psychologist who practices in California, conducted a survey of custody evaluators about PAS (64). Twenty-one completed surveys were obtained. He sought to determine whether there was a constellation of identifiable signs and symptoms in the alienating parent, target parent and the child which, occurring together, could be said to constitute a syndrome as Gardner suggests. For the purposes of the survey, Nicholas defined PAS as the conscious or unconscious attempt by one parent to pro gram or coerce a child against the other parent; whether or not any notable negative feelings, attitudes or behaviors were observed in the child. Parent alienating behaviors were found to be highly correlated with children's alienation symptoms and vice versa. There were no significant correlations between the child's alienation symptoms and 8 of 10 target parent characteristics. Significant correlations were found, however, between child alienation symptoms and two target parent items: 1) withdrawing or temporarily giving up on the child and 2) becoming irritated and angry with the child for exhibiting the alienating behaviors. The findings of Nicholas' survey lend support to Gardner's contention that the core dynamic in PAS is between the alienating parent and child, and that the target parent's behavior is much less likely to be a major contributing factor. The majority of evaluator/respondents in Nicholas' survey reported that in about one-third of their custody evaluation cases, one parent was engaging in identifiable alienating behavior. In about one-fourth of cases, evaluators' recommendations were affected by the alienating parent's behavior.

According to Stahl, another California psychologist, PAS is one of the most complex issues custody evaluators may be called upon to assess, along with allegations of spousal or child abuse and parent requests to relocate (65). He is working on a new book with more intensive discussion of PAS. Hysjulien, Wood, and Benjamin devoted special sections to PAS, domestic violence and sex abuse allegations in their review of methods commonly used by custody evaluators, including interviews and psycho logical tests (66). There is no data which establishes the reliability and validity of such interviews, which are often quite informal and semi-structured.

Psychological tests which are used for the assessment of individual patients in clinical settings cannot be considered reliable and valid for the evaluation of family systems in forensic settings.

Stahl opines that many custody evaluations are not geared to adequately diagnose the pathology of an alienating parent and the complex family interactions which produce PAS (65). This results in recommendations which are too short-sighted for the true level of family dysfunction. He recommends that evaluators go beyond the confines of the individual, clinical assessment model and utilize Read More ..mprehensive, sophisticated methods, such as critically analyzing case material from a longitudinal perspective and comparing information provided by the parties during interviews with data from other sources.

Like PAS, Munchausen syndrome by proxy (MSP) is a complex psychosocial disorder which involves a number of individuals. Assessment models being developed for MSP are more esecially designed to assess issues of parental manipulation and deception, pathological parent-child relationships, and the recruitment by parents of professionals as "third party participants" in the parental agenda (13, 67). Complex deceptions by one or both parents in high conflict divorce pose serious challenges to the legal system (17, 18).

In an effort to upgrade and standardize the conducting of custody evaluations, the American Psychological Association (APA) published Guidelines for Child Custody Evaluations in Divorce Proceedings in 1994 (68). The Parental Alienation Syndrome: A Guide for Mental Health and Legal Professionals was one of three books by Gardner listed under pertinent literature. Montgomery expressed concern that custody evaluators were not using the APA guidelines and that this was contributing to serious decision errors in assessment and intervention with PAS and other high conflict cases (58). She pointed out that attachment theories derived from work with young children are being misused by custody evaluators to predict outcome for older children, another source of error. Like Kopetski's group, Montgomery expressed the view that attachment theory is of ten biased towards mothers and fails to take into account the fact that even young children will attach to multiple caregivers when the environment provides such opportunities and the child is encouraged to do so. In severe PAScases, Montgomery endorses the type of intervention strategies which Gardner proposes, e.g., placing the child with the target parent for several months.

According to Jones, Lund and Sullivan, who practice psychology in California, the protocols which Gardner prescribes for custody evaluations (48) enable evaluators to gain an in-depth picture early in the assessment process (52). These presenters use Gardner's diagnostic criteria for identifying PAS and believe it is important to educate the court about this diagnosis so that the court will deliver the appropriate legal intervention. However, they reserve the label PAS for severe cases, using "parental alienation" for lesser manifestations. Jones, Lund and Sullivan are conservative about recommending change of custody as an intervention but have occasionally done so in severe PAS cases. Sullivan classified alienating parents into "early and late starters." Early starters are those who begin generating the alienation dynamic early in the marriage. Late starters activate the alienation dynamic in response to a trigger event such as the separation and divorce process. Jones commented on the fact that severe parental alienation is a form of child abuse, especially when false allegations of abuse are involved.

Forensic Assessment of Sex Abuse Allegations

Gardner's work on PAS is frequently referenced in the literature on assessing allegations of sexual abuse (69-74). In the context of divorce, PAS is one of several possible explanations for abuse accusations. Mapes asserted that any professional conducting forensic assessments of alleged sex abuse, not just in family law proceedings, should be knowledgeable about PAS as a possible motivating factor for false allegations (75). The need for such knowledge is demonstrated in two of the case vignettes above, in which PAS was the cause of false allegations of abuse in juvenile court and criminal proceedings. According to Garbarino and Stott, adult misinterpretation and misunderstanding of children's statements has reached crisis proportions in legal proceedings of all kinds (16).

CONCLUSION

Parental Alienation Syndrome appears to be pervasive. The audience response during a recent presentation at the Second World Congress on Family Law made it clear that PAS is a social problem in other countries such as Canada and Australia (58). The probable range of variations in the presentation of PAS is likely to change according to the opportunities and limitations of the complex network of people and agencies who become involved. Outside social systems variously have the capacity to help ameliorate PAS or to further solidify it. When alienation becomes complete, it can amount to a de facto termination of parental rights. This includes the fact that PAS children experience the loss of nuclear and extended family, in addition to other long-term, detrimental effects. The judgments that courts and professionals make are difficult, complex and have far reaching consequences. Part III will explore the decision making process with respect to diagnostic issues and intervention strategies.