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Introduction

Custody assessments that include allegations of abuse and alienation are very stressful, not only for the parents but also for the CE who is presented with two convincing but conflicting stories. Often, it is difficult to differentiate whether the allegations are genuine or contrived. It is imperative that the CE resist the temptation and pressure to uncritically accept the child’s position, knowing that it is possible for children to be manipulated into having false ideas and holding manufactured feelings about a parent. Further, the CE needs to recognize that the targeted parent can be in a state of extreme distress and volatility as a result of the alienation and the fear of losing the children, which may be exacerbated by false accusations and from having his or her expressed concerns continually ignored. As a result, the behavior of the targeted parent should not be taken as a diagnostic indicator of the overall functioning and personality of this parent. Frequently, targeted parents have become educated consumers of the research and written resources on alienation and present to the CE conclusions regarding the alienating parent’s personality style/disorder. These negative statements need to be considered in the appropriate context and not necessarily indicative of badmouthing the other parent.

The custody evaluation in cases in which PA is a potential causal factor should include an assortment of assessment instruments in order to develop an accurate and complete understanding of the functioning of the parties and their inter-relationship and family dynamics, including interviews, standardized as well as non-standardized instruments, observation, collateral contact sources for investigation, and a review of the documents offered and those not offered but requested. Clearly, each case should be carefully considered and analyzed when determining which tools to use. Generally, constructing a customized package of assessment instruments may require hours of thought and planning. Alienation cases are different than standard custody evaluations. Each allegation must be addressed and resolved, with evidence, to determine parent and child credibility to the court in order to hope to stop the alienation. Often these false allegations receive honorable mention without them being addressed as core issues and examples of the more subtle attempts of child indoctrination and programming by the alienating parent. Assessment instruments can assist the evaluator in providing some of the evidence needed.

Although there are ethical guidelines governing all custody evaluations, those involving potential alienation need to be specially crafted to ascertain whether alienation exists; and if so, to explain the dynamics and causes as part of the empirically based evaluation. The evaluator must consider all of the issues relevant to the criteria set forth in the relevant state statutes pertaining to shared parenting responsibility and the best interests of the child. In every case, it is important that the CE be court appointed, as opposed to retained by one side, in order to ensure impartiality and credibility.

Disputes sometimes erupt in court regarding the appointment of a custody examiner, with the favored parent objecting to a CE with experience in PA. This issue can become sidetracked with arguments about whether alienation exists and whether it should be classified as a syndrome. This debate is beyond the scope of this chapter and the reader is referred to Parental Alienation, DSM 5, ICD-II (Bernet, 2010). Like Gardner (1998) as well as Kelly and Johnston (2001) and Johnston and Roseby (1997), the position taken herein is that some children can be manipulated by a parent to unjustifiably reject the other parent whereas other children have valid reasons for their rejection. Differentiating the former (alienation) from the latter (estrangement) is a major focus of the work of a CE where children have become aligned with one parent against the other. In doing so, the evaluator must consider each factor that could explain a child’s expressing dislike for and resistance to contact with a parent. In other words, the evaluator must ascertain whether alienation or realistic estrangement or bona fide abuse is the underlying cause of the family dynamic (Sauber, 2010).

In making this differential diagnosis it is important to bear in mind the pressure (internal as well as external) that may impinge upon a CE’s ability to make a valid and impartial diagnosis. In particular, five factors may be present to compel a CE to conclude that the case is a hybrid (i.e., a mix of alienation and estrangement):

The CE may have been exposed to professional opinions that “most cases are hybrids.” While this may or may not be true in general, it certainly should have no bearing on the CE’s work in an individual case.
The favored parent may be particularly charming and persuasive about his/her victimization at the hands of the other parent and at the same time may pay lip service to wanting the children to have a good relationship with the other parent.
The aligned child may be very compelling, forceful, and emotional in his or her conviction about the inadequacy of one parent and the numerous excellent qualities of the other.
There is always some flaw in the rejected parent (who is cast as too weak/too strong, too messy/too tidy, and so forth) such that the rejection of the child might appear to be a plausible and rational response to that imperfection.
Concluding that a case is a hybrid may be more comfortable for the CE who is equally casting blame among the parties.
Concluding that a case is a hybrid may also be more comfortable with the judge, whom the CE wants to please in order to be the recipient of future referrals. In this sense, the hybrid solution is an easy way out for the CE, for whom concluding alienation is present may represent an inconvenient truth.

If the CE determines that a child has been alienated from one parent by the other, the CE must recognize that alienation is a serious form of psychological and emotional abuse having a significant impact on the alienated child throughout his or her life (Baker, 2007).

This kind of work is not for everyone. Mental health professionals wishing to enter family forensic work should consider obtaining supervised training or beginning as an assistant evaluator in these cases. Individuals lacking sufficient experience in such evaluations should have a mentor or supervisor to work with in order to avoid the “landmines” and traps set up by the alienator and attorney to compromise and undermine the evaluation. The transition from classroom to the courtroom is a complex, tension-producing, and difficult path in alienation cases and to think of these evaluations as being no more difficult than other evaluations is a mistake. One’s license may be challenged through the alienator’s complaints to the state regulating boards and each parent and their advocating attorney are prepared to use every legal tactic to assert the advantage to their position. Nonetheless, it is the mission of the evaluator to be the just presenter of the facts, offering an experienced and substantiated opinion rather than being concerned with potential complaints and defending his or her work-product from public critique and state regulators.

Components of a Custody Assessment

Document Review

A review of the documents is essential in order to learn what has happened, what is happening, and what is expected to happen. The attorneys and/or their clients select documents they believe to be essential for the evaluator’s review. This usually includes recent motions and cross-motions, transcripts from prior hearings, the original marital separation agreement (if one exists), and prior evaluations and affidavits from collateral sources, as well as video tapes and copies of correspondence between the parties. Once the evaluator has an initial understanding of the case, documents not originally submitted in the original package may be requested. It should be expected that as the evaluation proceeds, the clients and attorneys will send additional documents that were intentionally or accidentally omitted in the initial packet, such as police reports, school attendance records, pediatric information, and/or domestic violence court information forms, as well as e-mail correspondence between the parties. The evaluator can also make a list of other information to request. Reviewing the basic documents takes place as part of the process of becoming acquainted with the case and the parties whereas the final review of the documents may not occur until late in the evaluation. For example, it may be that several police investigations and findings with child protection services were “unsubstantiated” and, therefore, they were not submitted, but reading the actual report, nonetheless, may be quite revealing and it could be requested if not originally submitted. Toward the end of the evaluation the CE may obtain this additional information, which takes on a different relevance and significance with respect to the intentional distortion of facts, who filed or called the authorities to investigate, whether there was sufficient valid information to make a determination, the cooperation level of the parties, whether the recommendations offered by the Department of Children and Families were followed or ignored, and so forth.

Parent Interviews and Assessments

Individual interviews with each parent form an important part of any custody evaluation. It should be expected that the parents have given much thought about what they want to say and how they want to express and present themselves. However, it is probably true that no matter how much planning for “impression management” the parent has engaged in, once in the examining room, the parent’s emotional energy is likely to take over and can be very revealing. Conducting a psychosocial history will be useful for forming competing hypotheses. In addition, asking parents about how they provide guidance, affection, limits, and discipline to the children is a good place to start these discussions. The evaluator is cautioned not to interrupt and only to offer empathetic patience. Listening and note-taking is the role of the evaluator in this first meeting with the parents after having explained the purpose of the evaluation, the limits of the CE role, and the procedures to be followed. As time goes on, the evaluator may ask a parent pointed questions based on apparent discrepancies or gaps in his or her story. Knowing that custody evaluations in general are oriented towards parent’s efforts at presenting positive impressions and covering up deficiencies, alienation examinations will be replete with deceptions, distortions, and corrupt manipulations intended to mislead even the most experienced CE.

In conducting parent interviews, some evaluators work from a prepared list of questions while others spontaneously ask questions that follow from the client’s responses and the flow of the conversation based upon their training and experience. Either approach or a combination of both is acceptable, as long as the evaluator is aware of the process taking place and is flexible enough to pursue new directions that may be uncovered as part of the process. Rigid procedures that demand completion of the interview in a fixed time format can be counter-productive in alienation cases. Specific to alienation cases, as opposed to general custody evaluations, the use of standardized questionnaires such as the Ackerman variety (e.g., ASPECT or the Quickview Social History published by Pearson/PsychCorp) is ill-advised or cautioned against.

While they are useful short cuts and efficient methods in obtaining information from the clients completing the questionnaires, they obscure the spontaneous value of the skillful interviewer in discerning discrepancies, listening to the way in which allegations are described, and carefully noting the confabulations of past history taking and present storytelling. There is no substitute for the observation of the “here and now” in encountering the alienating or targeted parent that cannot be derived from reading questionnaires answered by clients controlling the pencil while they contemplate how to best respond to each item presented in the booklet. While engaged in the interview process, there are a number of themes or factors that the CE can bear in mind as potential “red flags” that alienation has occurred. Some of these have been compiled by Rohrbaugh (2008) based on research in the field (Clawar & Rivlin, 1991; Johnston & Roseby, 1997; Kelly & Johnston, 2001; Stoltz & Ney, 2002). These factors include an authoritarian or overly permissive parenting style, prior unresolved experiences of loss and separation, ineffective coping strategies (especially around loss), fear of abandonment, impaired ability to be empathic with the child and tolerate the child’s separate and unique experiences and needs, and whether either parent has a new partner who is viewed as a replacement parent for the children.

The potential motivation for a parent to want the children to reject the other parent must also be noted (Baker, 2007; Clawar & Rivlin, 1991; Gardner, 1998), including the desire for revenge, self-righteousness, fear of losing the child, jealousy, and financial incentives. The CE should bear these in mind as the personality and behavior of each parent becomes revealed through the interviews and observations. While these elements may reflect a natural human response to the challenge of divorce and custody conflict, many people are able to keep them in check. People with narcissistic or sociopathic personality disorders, however, are more likely to act on these emotions, leading them to sacrifice the child’s well-being and deny themselves the benefit of periodic breaks from childcare duties and the benefit of having a co-parent. They tend to believe the other parent is not only useless but actually a detriment to the children, who would be better served by no longer having that parent in their lives. Thus, an inability to contemplate the value of the other parent to the child is an alarm sounding for alienation, as that attitude sets the stage for tactics in the removal of that parent. Although parents in a high-conflict divorce may have difficulty in identifying strengths in the other parent’s contributions to the children, alienating parents in particular often will begin with a litany of complaints about the other parent’s weaknesses and express great difficulty in asserting any positive traits or characteristics that they would like their child to emulate, or to justify the need for that parent to play a meaningful role in the child’s life. By contrast, the targeted parent will speak in more moderated tones of their disappointment in the alienating parent’s anger and malicious tactics of revenge in disproportionate magnitude to the stated source of their rage. Some targeted parents express hope for the other parent to move beyond anger and begin to co-parent in a constructive manner so that both parents can contribute to the lives of their children.

Discussion about enforcement of visitation will also be very instructive. It is relatively easy to recognize the targeted parent’s plight and agony of only wanting to love and be with the children while the children are vocalizing terrible things about that parent, whom they say they hate and despise, and whom they profess to never want to see again. At the same time, the alienating parent typically has a long list of punishments and restrictions that they would like to see imposed on that parent, which would most likely result in the crippling of the rejected parent’s ability to maintain or re-establish any meaningful relationship with the children. Other alienation clues include a parent claiming to be unable to enforce visitation (while managing to elicit cooperation from the children for every other aspect of their lives, including completing homework, attending school, doing chores, and so forth) and a parent claiming to support the child’s decision regarding visitation (when the parent does not allow the child to make other equally important choices, such as which school to attend, whether to have vaccinations, and so forth).

It is also useful to ask a parent about their views of the other parent’s parenting capacities. Although there are a variety of parenting assessment tools (e.g., the Parent–Child Relationship Inventory and the Parenting Stress Index), none of these measurement instruments specifically address the issues of alienation. Utilizing open-ended questions about parenting behavior and perceptions of the other parent can be quite helpful in obtaining insight into how each parent perceives the other parent’s abilities and related personality traits. Asking about the other parent’s contribution to child rearing will produce contrasting viewpoints, with the favored parent being hard-pressed to admit that the other parent actually participated in any aspect of the children’s upbringing. Targeted parents, on the other hand, often describe a more mixed picture, being able to appreciate the good that the favored parent has done for the children.

Likewise, each parent should be asked about his/her strengths and weaknesses and those of the other parent. Alienating parents will be unable to identify a single strength of the other parent, while targeted parents will usually concede that the other parent loves the children while being misguided in his or her expression of that love. Asking how they would like their child to grow up, similar to and different from the other parent, can be revealing as to whether they hold rigid black/white views of the other parent or whether they can retain perspective and appreciation for that parent’s positive contributions to the child. Parents who present a picture of the other parent as “all bad” and completely lacking any positive attributes are likely to present this view to the child and contribute to the alienation. A Scale for Parental Competency of the Other Parent has been developed (Sauber, 2010), which may prove useful. The parents are given the option to discuss or exchange their ratings with one another, hoping to provoke discussion, confrontation, and clarification. In one case, the favored parent was “forced” to admit on the scale that the rejected parent was “a competent parent” despite her extensive criticism of him to their children and the court.

Family History

The initial interviews with each parent should include a detailed gathering of family history. The history of the parent as an individual and as a child growing up is relevant and necessary to understand the personality, attitudes, emotional problems, priorities, and life position of that parent. A complete and detailed history of each parent sheds light onto his or her beliefs about parent–child relationships and can suggest possible mental disorders and/or agendas of the parent which need to be addressed in the evaluation process. For example, a history of abandonment may suggest the likelihood of a borderline personality disorder, leading the evaluator to administer the Inventory of Altered Self-Capacities. Perhaps a mother was sexually abused as a child and worries that her former husband may do the same to their daughter although there are no indicators that this would be the case. By considering the family history, the CE can determine if there is a foundation for boundary violations which may explain parentification (viewing the child as an extension of oneself). Obtaining a personal and family history will include inquiring about substance abuse as well as about sibling relationships, dating history, conduct and performance in school, and parent involvement and discipline, plus childhood activities and interests. All of this information will enrich the CE’s understanding and appreciation of the motives and behavior of the parent, and be useful for hypothesis testing and elimination of alternative explanations.

Personality Assessments Personality inventories provide one way of obtaining information and determining consistency in findings. Use of these instruments is recommended by both the American Psychological Association (1994) and the Association of Family and Conciliation Courts (AFCC, 2006). The evaluator needs to be aware of the psychometric properties of any instrument that is administered, including its strengths and weaknesses and the appropriate sample of individuals for whom the test is intended. Frequently, psychopathology of the alienating parent can be identified in the use of personality inventories such as the Minnesota Multiphasic Personality Inventory-2 or MMPI-2 Restructured Form, the Personality Assessment Inventory, and/or the Millon Clinical Multiaxial Inventory-III. These tests also provide an index of validity and lying, or truth and honesty, versus intentional distortion of items and presenting socially desirable responses to certain items, all of which are highlighted in the validity scales.

Cases of alienation often challenge the evaluator to be aware of “impression management,” with both parents diligently presenting their side of the story in which their faults are minimized in comparison to those of the other parent. Some targeted parents are able to concede that they are not perfect parents and admit they may have to some degree caused conflicts with their children. While personality tests are not expected to directly detect or lead to conclusions related to alienation, these scales often provide useful information towards a better understanding of the parents. For example, a parent who scores high in terms of sensitivity to perceived or actual abandonment by significant others, and may rely on his or her identity as emanating from their role as a parent, may be more prone toward alienation than a parent who does not demonstrate these characteristics. However, it is imperative to ensure that the test data are not “over-interpreted” and undue reliance is not placed upon them. Ideally they are used to generate hypotheses, which then require corroboration from other sources.

Projective Tests Projective techniques such as the Thematic Apperception Test (TAT) for storytelling, drawings, and completing sentence blanks can be useful for gaining insight into the world and family view of parents and children. However, projective assessment offers opportunity for the opposing attorney to criticize because of their lack of objective scoring and established validity. Nevertheless, their use has survived the test of time and this form of assessment can provide extremely valuable information because the “right” answer is not always easy to detect by the person being evaluated. The evaluator should devote as many hours as is necessary to carefully selecting which projective measure to use and how best to administer it, knowing that events that occur just before the administration of the test can impact the results, such as which parent is in the waiting room, who brought the child, whose house the child was residing at prior to the testing. Unique to custody evaluations are TAT-like pictures of family conflicts and courtroom settings that provide the opportunity for the parties involved to project their stories of what is happening, what led up to the situation depicted in the picture, and what will happen. Selection of different items from different sets is acceptable as long as the evaluator can defend the choices. Often these instruments offer face validity, as one child described a courtroom picture in which he said his mother was telling the judge that his father was abusive to the children. Upon inquiry, the child admitted he did not know what “abusive” meant.

Parent Feedback

The evaluator may choose to administer a consumer satisfaction scale for parents “to evaluate the evaluator” (Sauber, 2009). This should be accomplished in person on the last session prior to any reports being released, although some collateral interviews may still take place. The form may already exist or can be constructed by the evaluator. The measure should include items about the evaluator’s observational and interview skills as well as rapport building with children. Should the ratings be favorable, once the report is issued and one side begins to object to the findings, the scale can be useful to indicate that the evaluation and its various components were acceptable to both parties prior to their reading the final report and its recommendations.

Interviewing Collateral Sources

A collateral contact is any person outside the immediate family who can contribute information about the family to the CE. Collaterals can be professionals involved in the case (e.g., the child’s therapist, a school guidance counselor, the pediatrician) or can be friends and extended family members of the parents. It is not assumed that these sources are impartial or neutral. The AFCC (2006), in its Model Standards of Practice for Child Custody Evaluations points out that:

Valid collateral source information is critical to a thorough evaluation … In utilizing collateral sources, evaluators shall seek information that will facilitate the confirmation or disconfirmation of hypotheses under consideration.

Gould and Martindale (2007) assert that:

The acquisition of reliable and relevant collateral information is arguably the most important component of a child custody evaluation. Information from people who have direct observational knowledge of the parent and child in different situations may be among the most important data obtained in a child custody evaluation. (p. 106)

In cases unique to alienation, the evaluator can never second-guess the provided list of collateral contacts. Some contacts will provide reflexive and automatic support for the parent with whom they are aligned. However, others may actually reveal a surprising amount of independence of thought and opinion and offer useful insight into the family dynamic. For example, in one case an alienating mother listed her sister as a reference. When contacted by phone, she described the father as the primary parent with respect to the children’s extra-curricular activities for many of the years preceding the marital separation. The sister’s report was counter to the impression given by the mother and daughters, who claimed that the father had never shown any interest nor was he ever involved with his children in their after-school and community activities. The mother and daughters explained that it was his lack of interest that resulted in an absence of bond between the children and their father, justifying their refusal to ever see him again.

Ideally, every recommended collateral should be contacted. In order to make this manageable, it may be helpful to limit the time devoted to each interview. The interviews can be conducted in person or by phone. Careful questioning can bring out a benefit of almost every discussion. For example, in one case the evaluator asked the maternal grandmother why her alienating daughter called the police and filed a missing persons report and kidnapping charge against the father during his parenting time, as opposed to simply calling her former husband at his home or his office to inquire about the whereabouts of or speak to their children. The grandmother responded by asking, “Whose side are you on?” revealing the kind of tribal warfare that is consistent with alienation (Warshak, 2010). Sometimes, children can be encouraged to bring a friend with them to an interview, which can result in helpful information being revealed by someone who has close contact with the child and their family but is outside the reach of the alienating parent’s programming effort. Of course, permission is required from the child’s parent.

Observations of Parents and Children It is imperative to conduct observations of the parent–child interactions, including siblings in various combinations. These can take place in the parent’s home or in the CE’s office. Special attention should be paid to the child’s degree of comfort with each parent as well as the child’s reactions, emotions, and spontaneity, all of which are extremely important for recognizing discrepancies between the child’s statements during interviews and the child’s actual behavior. Comparing the child’s behavior when in the presence of that parent with the child’s ratings about each parent can be extremely informative (e.g., by using the Scale for Children of Divorce: Parental Preferences1). Some alienated children claim to be terrified of the rejected parent but in that parent’s presence they are provocative, rude, arrogant, and disrespectful, hardly the behavior of a frightened child. Likewise, some children who proclaim to hate a parent may actually express feelings of love, security, and playful enjoyment when alone with that parent. Without direct observation, it is easy to be misled. Particular attention should be paid to whether the child is equally compliant and respectful to each parent. If the child is pleasant and cooperative with the favored parent and rude and disrespectful with the targeted parent, the CE is able to observe what is situational (depending upon the parent in the room) and what is characteristic of the child regardless of which parent is present. Because some siblings function as “assistant alienators” (reporting to the preferred parent if a child demonstrates any affection to the rejected parent), each child should be seen alone with each parent in order to eliminate any potential undue influence of a surrogate alienator.

Child Interviews

At some point during the custody evaluation, each child over the age of 3 years should be interviewed alone. Child interviews occur after the process has been explained to the child, often in the context of a brief family orientation session. The timing of the interview, what questions to ask, and who brings the child to the office should all be given careful consideration. Being sensitive to the themes of alienation, asking opened-ended questions, and not challenging inconsistencies prematurely is essential. Asking the child to elaborate and further embellish his/her stories, sometimes to the point of absurdity, and asking the child about his or her understanding of each parent’s position is a useful strategy and will assist in the diagnosis of alienation and its severity.

Children’s Exposure to Parent’s Alienation Behaviors

Baker and Fine (2008, and this volume) have identified 17 parental behaviors associated with alienation because they induce children to unjustifiably reject the other parent. They include: badmouthing, limiting contact, withdrawal of love/getting angry when the child is positive towards the other parent, telling the child that the targeted parent does not love the child, forcing the child to choose/express loyalty, telling the child that the other parent is dangerous, confiding in the child about adult relationships, limiting photographs of the other parent, forcing the child to reject the other parent, cultivating dependency on the alienating parent, asking the child to spy on the other parent, telling the other parent that the child does not love him or her, referring to the other parent by his or her first name, referring to someone else as “Mom” or “Dad,” having the child keep secrets from the other parent, and changing the child’s name. The evaluator should keep these behaviors in mind when talking with the children about the parents.

Children’s Exposure to Programming

In speaking with children, the evaluator should ascertain whether or not they have been exposed to parental programming efforts (Worenklein, 2010) by considering Rohrbaugh’s suggested questions based on Clawar and Rivlin’s (1991) detection factors. Some of these questions are closed-ended and may be considered too leading, and are offered for illustrative purposes in Table 3.1 as to the type of question with which to engage the children in conversation rather than as the actual question.

Children’s Manifestation of the Eight Symptoms of Alienation

As noted throughout this chapter, alienation refers to cases in which a child has been manipulated by one parent to unjustifiably reject the other parent. Not all children who reject a parent, however, do so because of alienation. When a child has a valid reason to reject a parent, such as abuse, neglect, or abandonment, the term “realistic estrangement” is appropriate. As the opening vignette demonstrates, sometimes it is difficult for non-professionals and some mental health professionals to recognize whether the child’s refusal to spend time with one parent is the result of alienation or estrangement. Gardner (1998) identified eight behaviors that he found (and that have now been supported by research and clinical observations [Evans & Bone, 2011]) to differentiate alienation from realistic estrangement, as shown in Table 3.2.

Table 3.1 Indicators of alienation that may be detected through child interviews

Indicator

Question

Child’s answer that reflects alienation

Forbidden to love both parents

“Do you feel free in your heart to love both of your parents?”

“Dad said that if I go to live with Mom I’ll never see him again.”

Inappropriate and unnecessary information

“Is Mom/Dad upset about anything special that you know of?”

“My Dad was having an affair while my Mom was having me in the hospital.”

One parent seen as martyr

“Is there something that you think could happen that would make the family situation better now?”

“Mom destroyed our family with this divorce. Dad always says that he still loves her and that she can come back.”

Contradictory statements

“How do you feel about your dad?”

“Daddy’s a bad man. I never want to see him again. But I really love him. I miss him a lot.”

Use of indirect statements quoting brainwashing parent

“How did this weekend go? Does Mom have an opinion about the time you spend at Dad’s?”

“When I get home Mom says things like, ‘Too bad you had to go with your dad this weekend—you missed a great ski trip. I bet you only watched TV.’ As usual, Mom’s right, Dad is boring.”

Character assault on target parent

“What do you like about being at Mom’s?”

“Mommy has lots of boyfriends who sleep over. Daddy says she’s a whore because the Bible says so.”

Anxiety arousal

“Are there things that are upsetting to you now?”

“Mom and Dad [the stepfather is called ‘Dad’] have to listen when Steve [biological father] telephones us because if he finds out where we live, he might kidnap us.”

Good parent versus bad parent

“How do you feel about Mom at this point?”

“I know Mom is bad because Daddy says so, and I believe everything he says. My dad never lies to me.”

Collusion or one-sided alliance

“Sometimes children think things may be unfair. Is there anything that you think is unfair?”

“Dad just bought a new car but Mom’s poor—he should have given us the money.”

Scripted views

“You said you were confused about the fight and what really happened. What does Dad think happened?”

“I really thought I saw Dad’s girlfriend hit Mom first but Dad says he saw Mom start it. I’m confused now.”

Changed and dysfunctional behavior outside family

“I heard you’ve become a really good student—even better than before. Why do you think this has happened?”

“My grades have really improved since Mom and Dad decided to split. I figured out it’s because school is the only place where I can escape.”

Guilt about own role in family or custody dispute

“Is there anything that you feel guilty about since this whole family change started?”

“I testified against my mom in court, and I lied to the judge.”

Nonverbal messages

“People can send messages with words and with gestures. Does Mom/Dad use gestures? How?”

“I know Dad doesn’t want to hear anything about Mom. If we did something special with her, and we’re still excited when we see him, he acts [looks away as if to imitate Dad] like he doesn’t care.”

Child as spy or conduit of information

“Is there anything that you’ve done during your parents’ separation that makes you feel not as good as you’d like about yourself?

“I brought Mom some of Dad’s business receipts to help her in court because he says he has no money.”

Age-inappropriate statements

“When you talk about your father, you use the word ‘father’ but when you talk about your stepfather, you use the word ‘Dad’.

“Anyone can be a father but it takes someone special to be a dad.” Could you tell me why you use different names?

Colludes in secret-keeping

“Are there secrets that are bothering you about this whole custody problem?

“Dad told me to keep this a secret, but we’re running away if he loses in court.”

Coaching behavior

“How do you know that?”

“My mommy told me to tell you he did.”

Confusion about birth parent

“Could you explain how your stepfather became your ‘real’ father?”

“My mom and dad got married, had me, and then divorced. They [mother and stepfather] told me that now I have a ‘real’ father. Can you tell me how I got born again?”

Fear of contact with target parent

“You say you pray every night. Are Mom and Dad in your prayers?”

“We read the Bible every night and pray for Dad to get better. I don’t know what’s wrong with Dad but I hope he’ll be okay. Maybe he’s even dangerous because we’re not allowed to give him our telephone number or address.”

Child statements mirror those of brainwashing parent

“Why do you think your father is trying so hard to make sure he has more time with you?”

“Dad doesn’t really love me or want me to live with him—he just wants custody to hurt Mommy.”

Unmanageability for no apparent reason

“Are there things that you’d like to be able to tell Mom/Dad, but find it difficult?”

“Yeah. I miss Dad, but I can’t tell Mom. It’s because of her that I don’t see him and we moved so far away. I was always really bad when I was with him. I think Mom liked it when I gave him trouble. I wish so much that I could tell her that I want to see him.”

Brain-twirling confusion, anxiety alliance, and hostility

“On the one hand, you say that the joint custody was good in a lot of ways. On the other hand, you say you don’t want it any more. How come?”

“I always thought I wanted joint custody [equal time in this case], and it was working in the beginning. But then my dad started so much trouble with Mom, it just isn’t worth it anymore.”

Child as parent’s confidant

“You have some criticisms of how your dad treats you. Are there things that your dad could do to improve the relationship between the two of you?”

“Dad treats me like a baby. He won’t tell me anything or even let me do the things Mom lets me do. My mom and I are more like best friends than mother and daughter.”

Fear for own physical survival

“Is there anything scaring you at this time?”

“Sometimes I’m afraid of my mom. She loses it a lot lately. I’ve been slapped around. She’s really a lot rougher on my sister, especially when she tells Mom that she wants to live with Dad. I’m too smart to get her that mad—as long as I keep my mouth closed, I’m safe.”

Child threatens parent

“I heard that you said you wanted to tell the judge certain things about your mom. What’s the story?”

“Yeah, I told my mom she better do what I want because my dad told me I should tell him whenever Mom does something wrong, because the judge will punish her.”

Table 3.2 The eight behavioral manifestations of parental alienation syndrome and their detection in child statements

Indicator

Question

Child’s answer that reflects alienation

Forbidden to love both parents

“Do you feel free in your heart to love both of your parents?”

“Dad said that if I go to live with Mom I’ll never see him again.”

Inappropriate and unnecessary information

“Is Mom/Dad upset about anything special that you know of?”

“My Dad was having an affair while my Mom was having me in the hospital.”

One parent seen as martyr

“Is there something that you think could happen that would make the family situation better now?”

“Mom destroyed our family with this divorce. Dad always says that he still loves her and that she can come back.”

Contradictory statements

“How do you feel about your dad?”

“Daddy’s a bad man. I never want to see him again. But I really love him. I miss him a lot.”

Use of indirect statements quoting brainwashing parent

“How did this weekend go? Does Mom have an opinion about the time you spend at Dad’s?”

“When I get home Mom says things like, ‘Too bad you had to go with your dad this weekend—you missed a great ski trip. I bet you only watched TV.’ As usual, Mom’s right, Dad is boring.”

Character assault on target parent

“What do you like about being at Mom’s?”

“Mommy has lots of boyfriends who sleep over. Daddy says she’s a whore because the Bible says so.”

Anxiety arousal

“Are there things that are upsetting to you now?”

“Mom and Dad [the stepfather is called ‘Dad’] have to listen when Steve [biological father] telephones us because if he finds out where we live, he might kidnap us.”

Good parent versus bad parent

“How do you feel about Mom at this point?”

“I know Mom is bad because Daddy says so, and I believe everything he says. My dad never lies to me.”

Collusion or one-sided alliance

“Sometimes children think things may be unfair. Is there anything that you think is unfair?”

“Dad just bought a new car but Mom’s poor—he should have given us the money.”

Scripted views

“You said you were confused about the fight and what really happened. What does Dad think happened?”

“I really thought I saw Dad’s girlfriend hit Mom first but Dad says he saw Mom start it. I’m confused now.”

Changed and dysfunctional behavior outside family

“I heard you’ve become a really good student—even better than before. Why do you think this has happened?”

“My grades have really improved since Mom and Dad decided to split. I figured out it’s because school is the only place where I can escape.”

Guilt about own role in family or custody dispute

“Is there anything that you feel guilty about since this whole family change started?”

“I testified against my mom in court, and I lied to the judge.”

Nonverbal messages

“People can send messages with words and with gestures. Does Mom/Dad use gestures? How?”

Child as spy or conduit of information

“Is there anything that you’ve done during your parents’ separation that makes you feel not as good as you’d like about yourself?

“I brought Mom some of Dad’s business receipts to help her in court because he says he has no money.”

Age-inappropriate statements

“When you talk about your father, you use the word ‘father’ but when you talk about your stepfather, you use the word ‘Dad’.

“Anyone can be a father but it takes someone special to be a dad.” Could you tell me why you use different names?

Colludes in secret-keeping

“Are there secrets that are bothering you about this whole custody problem?

“Dad told me to keep this a secret, but we’re running away if he loses in court.”

Coaching behavior

“How do you know that?”

“My mommy told me to tell you he did.”

Confusion about birth parent

“Could you explain how your stepfather became your ‘real’ father?”

“My mom and dad got married, had me, and then divorced. They [mother and stepfather] told me that now I have a ‘real’ father. Can you tell me how I got born again?”

Fear of contact with target parent

“You say you pray every night. Are Mom and Dad in your prayers?”

Child statements mirror those of brainwashing parent

“Why do you think your father is trying so hard to make sure he has more time with you?”

“Dad doesn’t really love me or want me to live with him—he just wants custody to hurt Mommy.”

Unmanageability for no apparent reason

“Are there things that you’d like to be able to tell Mom/Dad, but find it difficult?”

Brain-twirling confusion, anxiety alliance, and hostility

“On the one hand, you say that the joint custody was good in a lot of ways. On the other hand, you say you don’t want it any more. How come?”

“I always thought I wanted joint custody [equal time in this case], and it was working in the beginning. But then my dad started so much trouble with Mom, it just isn’t worth it anymore.”

Child as parent’s confidant

“You have some criticisms of how your dad treats you. Are there things that your dad could do to improve the relationship between the two of you?”

“Dad treats me like a baby. He won’t tell me anything or even let me do the things Mom lets me do. My mom and I are more like best friends than mother and daughter.”

Fear for own physical survival

“Is there anything scaring you at this time?”

Child threatens parent

“I heard that you said you wanted to tell the judge certain things about your mom. What’s the story?”

“Yeah, I told my mom she better do what I want because my dad told me I should tell him whenever Mom does something wrong, because the judge will punish her.”

Assessing the Veracity of Allegations

An important function of the data collection efforts on the part of the CE is to understand and then evaluate the validity of each parent’s allegations against the other. For example, if the favored parent is correct that the rejected parent is abusive/coercive or uninvolved/neglectful, then the children’s resistance to visitation would be considered an indication of estrangement. On the other hand, if the rejected parent’s accusations are accurate that the favored parent has manipulated the children, poisoned them against him/her, and there was no justified reason for the rejection, then the resistance of the children would be considered a reflection of alienation. No custody evaluation is complete without a thorough understanding of the truthfulness of the accusations made by and against each parent. The first step in this process is to ask the parents to make a list of each of their allegations. The next step is to ask them to repeat this assignment at another time in order to ascertain the consistency of the complaints. The third task is individually to discuss and question each and every item with the clients. In this way, the evaluator will have a complete accounting of each of their objections, complaints, accusations, and possible confabulations.

The follow-up during the process of the evaluation consists of examining every allegation. The confirmation or refutation requires sufficient evidence to justify the initial (working) and final hypothesis. There should be consistency in the parents’ complaints; and if not, questions should immediately be expressed and then the client gently confronted by the examiner. For example, a mother had stated on one of her lists that she suspected the father had molested their 12-year-old daughter, who refused to visit her father. Upon inquiry, the mother admitted that she did not really believe the father inappropriately touched their daughter but she could not offer any other reason for her daughter’s behavior. The actual reason for this refusal was later determined to be the result of her daughter suffering from maternal separation anxiety, which had nothing to do with the father and everything to do with the mother’s psychopathology. Thus, as the mother discussed her list of allegations with the evaluator, she chose to withdraw the sexual abuse claim realizing that this was such a remote possibility and she had no justifiable reason to believe her own suspicion. Unfortunately, allegations take on a life of their own, become reified as if they were true, and as time continues they become more difficult for the child to believe that they originally were fabricated (Sauber, 2010). Nonetheless, the CE remains outside the influence of the family myths and objectively examines the allegations with a fresh and impartial stance.

Generally, most or at least part of the accusations made in the context of a custody evaluation are false. Unfortunately, if the allegation proves to be false there are often few, if any, consequences for the fabricator.

Too often, no one seems to care if a false allegation is made; and at most, the parent who made the claim is reprimanded by the presiding judge for wasting the time of the county’s child protection services and possibly the police force, and unnecessarily requiring the court’s attention. For the CE, however, veracity of the allegations is essential because it is relevant for ascertaining the cause of the child’s visitation refusal/rejection of the other parent and the credibility of the parent making the claim. If false allegations have been made, it behooves the CE to explore the details with the favored parent in the context of the deliberate intention of that parent to obstruct visitation in order to enjoy unilateral decision-making. The alienator is likely to justify exclusion of the other parent based upon spurious claims, trying to draw attention to the fictitious allegations. Rather than seeming relieved to discover the allegations are unfounded, most alienating parents will maintain a firm belief in the abusiveness of the other parent regardless of the report by the authorities. In this way, the fabrication of the allegation calls into question the credibility of the fabricator. It is essential that the CE pursue this matter of credibility and begin to list other false allegations so that in the CE report and testimony it becomes incontrovertible evidence that the alienating parent has repeatedly lied, misrepresented the “facts,” and brought in third parties intentionally to mislead the court. Most insidious is the negative impact on the child, who either has to experience a child protection investigation or partake in parental collusion to support or to be the focal point of the false allegation against the other parent.

If the evaluator determines that one parent’s accusations about the other parent are true, the CE may need to bring this finding to the attention of the court, which is likely to take action under these circumstances. The CE must be well versed in child abuse reporting laws and should understand that there can be no error on the part of the evaluator. If there is doubt or the evaluator feels that the issue to be examined escalates beyond the examiner’s expertise, this information needs to be immediately communicated to the court. The evaluator may request in writing that an expert in the identified specialty area be appointed to assist with the evaluation. Another option to consider is for the evaluator to seek a supervisor to review the evaluation process, methods, and findings, payment for which would be the responsibility of the evaluator, not the client(s).

Making a Determination of Alienation

The determination of alienation as the cause of the children’s visitation refusal/rejection of the other parent is based on the culmination of the evidence collected during the course of the evaluation. It is vital for the CE to hold an open mind as to the ultimate question until all of the data have been collected in order to avoid confirmatory bias (i.e., paying more attention to the evidence that supports the hypothesis/conclusion than to evidence that does not support it). While there is no single formula that can be applied to each case, it is helpful to consider the following four steps presented by Baker, Burkhard, and Kelly (2012): Presence of a positive relationship prior to the current visitation refusal/rejection. Absence of abuse/neglect on the part of the now rejected parent. Use of PA strategies on the part of the favored parent. Exhibition of many of the eight behavioral manifestations of alienation in the children.

If all four points are in the affirmative, then it is most likely that alienation is the cause of the children’s current rejection of the targeted parent. Where it becomes more complicated, obviously, are cases in which some but not all four points are affirmative, such as a case in which there has been a positive relationship with the targeted parent but that parent has shown a major lapse in parenting judgment which hurt the children. In response, the now favored parent has engaged in alienation strategies and the children show some but not all signs of alienation. In cases such as these, the clinical skills and judgment of the CE will be extremely important for arriving at clinically sound conclusions about the family dynamics underlying the children’s rejection of a parent. If it has been determined that the issue is one of alienation, then the focus becomes one of differentiating the classification as mild, moderate, or severe. Although each level affects the child in different ways and in varying intensities, the moderate and severe forms of alienation offer greater challenge because of their often chronic state of indoctrination. Moderately or severely alienated children express consistent negative feelings regarding the targeted parent, whether or not in the mother’s or father’s company, in the examiner’s office, in their school setting or on the playground with their friends, or in any other environment when the topic of parenting arises (Worenklein, in press). These symptoms appear with more complex, problematic short- and long-term consequences.

Custody Evaluation Conclusions and Recommendations

Some evaluators find that conclusions and recommendations are the most difficult to formulate and write and others have stated it is the easiest component to complete. This section of the report should always include any PA findings and these results should be intertwined with the state regulations and guidelines for shared parental responsibility and the best interests of the child, such as co-parenting, joint decision-making, and sharing medical and activity information. Conclusions and recommendations according to Warshak (2010) should include the following elements:

A detailed discussion of why there was or was not alienation or estrangement, focusing on each of the parent’s assessment results and statements as well as factual material, collateral sources, reactions, etc.
Detailed and clear recommendations with a focus not so much on labeling or blaming but on constructive interventions to reduce the conflict and normalize the relationship between the children and the targeted parent. Such recommendations should ensure the continuity of mental health professionals working with the family as well as one judge who remains with the case, and one CE who can be asked to provide the court with updates.
Discussion of whether the alienation, if present, is mild, moderate, or severe, and detailed reasons, if possible, using quotations from the parents or children.
Discussion of the effects of conflict on the children in light of child development.
Discussion of the present and future effects of alienation, if present.
Consideration of whether there needs to be a change of custody and whether there should be no contact for a period of time between the children and the parent with whom they are aligned. Generally, a change of custody should be considered only after taking into account the parental capacity, including strengths and weaknesses of the parent receiving custody, as well as the child’s circumstances. This is necessary in view of the significant behavioral and emotional challenges often found in the child who is severely alienated, and only with mental health interventions and support in place.
Recommendations for therapeutic intervention, and the nature of such intervention, by a professional who is qualified to deal with alienation issues.
Consideration of a parenting coordinator who is well versed and experienced in PA.
Recommendations for the parents in terms of how to protect the children from badmouthing, and other alienation strategies, and how to possibly use more effective communication strategies.

Too often, evaluators of contentious, high-conflict cases will want to offer “middle of the road” suggestions to appease each parent (i.e., concluding that every case is a hybrid case in which the favored parent has engaged in alienation but the targeted parent has exhibited flaws which equally contributed to his/her rejection). While it is certainly true that some cases are hybrid, there is no reason to believe that all cases are. In some cases, one parent is more to blame than the other for the child’s rejection of a parent and the CE must be able to state that truth, supported by evidence. Thus, it is vital that the evaluator be an experienced, thick-skinned, tough-minded professional who has and will exhibit the courage of his/her convictions. This stance contrasts with the tender-minded, sensitive, and gentle therapist whose aim is to develop rapport in order to build and maintain a relationship. What evaluators discover and believe will need to be disclosed with clarity and precision, without sugar coating.

Evaluators must not assume that they have to find something positive and negative about everyone to balance the evidence. In most divorces there will be both strengths and weaknesses of each of the parties. However, with PA cases being so vicious, replete with deception, false allegations, manipulations, exploitation, and impression management, it may be more difficult to find complimentary words to describe the alienator. It is the ethical duty of the evaluator to present, without bias, the true findings and not disguise or mitigate the findings for the purpose of self-protection or to protect the feelings of the parent.

Formulation of the actual conclusions and what recommendations make logical sense should be based on documented evidence in the report. Opinions can be used to supplement the objective evidence but they must have a rational and evidentiary foundation. The conclusions should bring to the fore the solution recommended and why and how to implement the justified change of circumstances. Recommendations should always include the statement that the judge will make the final decision beyond what is contained in the report through examination of all of the circumstances presented to the court and the history of evidence presented in the case. The evaluator should not mislead the clients since, at most, evaluators can only offer findings and recommendations but do not, cannot, and should not make decisions involving the case outcome. Ideally, the evaluation report may facilitate mediated settlements in the shadow of using the report findings in court.

Once the report is submitted—directly to the court and not to either party—no contact should follow with either party until approached by one or both of the attorneys. In one example, an attorney wrote a letter containing the client’s objections and errors in the report’s conclusions and recommendations and requested the evaluator to respond. The evaluator wrote back with a c. c. to the other attorney that no correspondence or verbal questions would be addressed other than in the format of a scheduled deposition.

Evaluators should expect that the attorney representing the client with the favorable outcome will wish to exploit the expert to support and extend the recommendations on behalf of his or her client. The attorney representing the client who receives an unfavorable recommendation is ready and willing to retain an expert to find flaws, shortcomings, and ethical violations in the methodology and procedure, and attack the findings in the report as well as the evaluator. Not surprisingly, the validity of the concept of PA is an area attorneys often focus upon because the criticisms are readily available. It is vital the CE know these criticisms and how to rebut them in order to avoid the recommendations being discounted as stemming from a spurious argument of an invalid theoretical basis.

The Written Report

In order to conduct a thorough and valid custody evaluation, the CE must be knowledgeable about psychological assessment, child development, and family dynamics, including alienation. Another skill set necessary is involved in the art of writing a technical, evidence-based report in a scholarly style designed to meet the standards of Frye or Daubert. The report must be clear and succinct, and outlined in such a way that the attorneys and judge easily can follow and make sense of the findings and understand the basis of the results and the facts that serve as the basis for the conclusions and recommendations, which flow from the consistent and substantiated procedure and methodology. The report must present the recommendations with full disclosure and acknowledgment that it is the judge who makes the decision after reviewing all of the reported evidence beyond what the report envisions as the solution.

Testimony

Testimony may or may not follow the report, depending upon the findings and other variables of the case, which may lead to settlement rather than litigation. However, in cases of alienation, winning at all costs often becomes paramount, such that the case often but not always proceeds to trial. When this happens, the evaluator becomes involved in the process: a deposition may occur to try to discover areas of weakness in the report and one side may retain an expert to review the report with the intended purpose of finding fault, arguing for dismissal of certain findings, and perhaps alleging ethical violations. It is vital to maintain impartiality; the evaluator ceases having contact with either of the parties until the trial date.

An obvious advantage is for the CE to be skilled in appropriate courtroom tactics and demeanor in preparation for cross-examination that is designed to discredit the CE and his/her findings. The evaluator must be prepared to explain his/her methods and defend the report and its conclusions. The CE must also be able to speak knowledgably and authoritatively about the theory and research on PA and to address the issues likely to be raised by opposing counsel, such as why PAS was not included in the Diagnostic and Statistical Manual of Mental Disorders and whether that indicates that PAS is not generally accepted by the scientific community. If these issues are not properly explained the entire report, including the conclusions and recommendations, can be “thrown out.” The evaluator must be educated and trained in clinical, family, and forensic psychology to do this type of work and should have a background beyond a continuing education course to understand the interface between the law and psychology and how to act as a guest in the court of law.

Finally, experts conducting forensic evaluations should require the parent(s) to sign an informed consent form, a release of information form to obtain records from the school, pediatrician, mental health professionals and others, as well as a fee schedule/retainer agreement during the initial meeting while the client completes a general intake information sheet. Court-ordered evaluations do not need informed consent because the court order states that the information is to be provided to the court in the form of a report and/or testimony, thus waiving confidentiality and privilege. The initial retainer needs to be replenished prior to the continuation of further work as there cannot be any balance due prior to the release of the report to the court and to the attorneys representing each client. Otherwise, the issue of a contingency fee will be raised and questioned as compromising the evaluator’s recommendation as impartial; further, the party receiving an unfavorable finding will likely refuse to pay any balance to support a finding that is contrary to his/her desires.

Unless the report takes a middle of the road, “everyone is a little bit to blame” approach (which may be true in some but not all cases) the CE is likely to disappoint and anger some parents and some attorneys. This work is not for the novice or approval-seeking mental health professional. The evaluator must be very familiar with alienation theory and practices, be able to recognize it when it is present, and have the courage of his/her convictions to describe it as it is, even when it is inconvenient and uncomfortable to one of the parties in the case.

The CE must be able to explain, describe, and defend each of the methods, procedures, and conclusions offered in the report. While these cases are extremely challenging, complicated, and often stressful, alienated children and targeted parents deserve high-caliber evaluations to bring to the fore the truth of the matter. Often, the cast of characters (e.g., the child’s therapist, the guardian ad litem and the children’s rights attorney, the parent coordinator and probably the judge as well) already have been persuaded, by the compelling stories of the children and the well-articulated complaints of the alienating parent, to shift the weight of emotions, not evidence, against the targeted parent in favor of the alienating parent. By the time that the CE is appointed to conduct an evaluation involving an alienation assertion, the opinions and attitudes have been formulated and the children are protesting contact with the rejected parent. The professionals sympathize with the children and often support their excuses for avoiding the previously agreed-upon visitation schedule now that they “know” and have been told how egregious the targeted parent has been. Enter the evaluator as the impartial expert, ordered under protest who must attempt to expose the truth in order to provide the judge with the evidence needed to make a fair and just ruling on behalf of alienated children and families. Welcome to the role of the evaluator in alienation cases!

Note

1In progress, a study of standardization of a measurement instrument to differentiate alienation, realistic estrangement, and bona fide abuse (S. R. Sauber & A. Worenklein).

References

American Psychological Association. (1994). Committee on Professional Practice and Standards. Guidelines for child custody evaluations and divorce proceedings. American Psychologist, 49, 677–680. Association of Family and Conciliation Courts. (2006). Model standards of practice for child custody evaluation. Family Court Review, 45(1), 70–91. Baker, A. J. L. (2007). Adult children of parental alienation syndrome. New York: W. W. Norton. Baker, A. J. L., Burkhard, B., & Kelly, J. (2012). Differentiating alienated from not alienated children: A pilot study. Journal of Divorce and Remarriage 53(3), 178–193. Bernet, W. (2010). Parental alienation, the DSM, and the ICD-11. Chicago: Charles C. Thomas. Clawar, S. S. & Rivlin, B. V. (1991).

Children held hostage: Dealing with programs and brainwashed children. Chicago, IL: American Bar Association Family Law Section. Evans, R. A., & Bone, J. M. (2011). Essentials of parental alienation syndrome. Palm Harbor, FL: Center for Human Potential of America. Gardner, R. A. (1998).

The parental alienation syndrome: A guide for mental health and legal professionals. Cresskill, NJ: Creative Therapeutics. Gould, J. W., & Martindale, D. A. (2007). The art and science of child custody evaluations. NY: Guilford Press. Johnston, J. R., & Roseby, V. (1997). In the name of the child: A developmental approach to understanding and helping children of conflicted and violent divorce. New York: The Free Press. Kelly, J. B., & Johnston, J. R. (2001). The alienated child: A reformulation of parental alienation syndrome. Family Court Review, 39(30), 249–266. Rohrbaugh, J. B. (2008).

A comprehensive guide to child custody evaluations: Mental health and legal perspectives. New York: Springer. Sauber, S. R. (2009). Parental alienation syndrome and conducting forensic evaluations. Presented at the Canadian Symposium for Parental Alienation Syndrome, Toronto, Ontario. Sauber, S. R. (2010). Why forensic evaluations are more effective than traditional psychotherapy in helping alienated children. Presented at the Canadian Symposium for Parental Alienation Syndrome, Mt. Sinai School of Medicine, New York, U.S.A. Stoltz, J. M., & Ney, T. (2002).

Resistance to visitation: Rethinking parental child alienation. Family Court Review, 40(2), 220–231. Warshak, R. A. (2010). Divorce poison: How to protect your family from bad-mouthing and brainwashing (revised ed.). New York: HarperCollins. Worenklein, A. (2010). Using the themes energizing parental alienation to identify and diagnose it. Presented at the Canadian Symposium for Parental Alienation Syndrome, Mt. Sinai School of Medicine, New York, U.S.A. Worenklein, A. (in press). Moderate parental alienation. In D. Lorandos, W. Bernet, & S. R. Sauber (Eds.), Parental alienation: The handbook for mental health and legal professionals. Chicago,