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 as sess 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 dis cussed 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).

Judge Tolbert on PAS

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

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.  Furthermore, " 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).

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 in volved 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 de signed 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 mod erate 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 in volved, 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.

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.

A list of case citations involving PAS can be obtained from Dr. Gardner's web site. The list is not necessarily up to date or exhaustive.   Dr. Gardner's address on the World Wide Web is: http://www.rgardner. com/refs.

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 de fined PAS as the conscious or unconscious attempt by one parent to program 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 extensive 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 psychological 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 more comprehensive, 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 specially 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).

Forensic Assessment of Sex Abuse Allegations

Gardner's work on PAS is frequently referenced in the literature on as sessing 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.

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ABOUT THE AUTHOR

Deirdre Conway Rand, Ph.D. practices clinical and forensic psychology out of her office in Northern California in Mill Valley.  She specializes in complex forms of emotional abuse, such as severe Parental Alienation and Munchausen Syndrome by Proxy (MSP). She is the author of several articles on MSP and of two chapters in the book, Spectrum of Factitious Disorders, published by the American Psychiatric Association in 1996.