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.

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.

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 bio feedback 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

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 par ents 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 to-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 de fined 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 en couragement 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.

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.

AMERICAN JOURNAL OF FORENSIC PSYCHOLOGY, VOLUME 15, NUMBER 4, 1997 / 69

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, intractable alienation.  She recommended the use of judicial sanctions to hold alienating parents accountable and to provide incentives for changing their behavior.

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