Archive for the ‘Journals’ Category

Denial of the Parental Alienation Syndrome Also Harms Women, Dr. Gardner. American Journal of Family Therapy

American Journal of Family Therapy 30(3):191-202 (2002).

Denial of the Parental Alienation Syndrome Also Harms Women

What’s good for the goose is good for the gander — Old Proverb

What’s bad for the gander is also bad for the goose — Richard A. Gardner

Richard A. Gardner. M.D.
Columbia University, New York, New York, USA

Denying reality is obviously a maladaptive way of dealing with a situation. In fact, denial is generally considered to be one of the defense mechanisms, mechanisms that are inappropriate, maladaptive, and pathological. In the field of medicine to deny the existence of a disease seriously compromises the physician’s ability to help patients. If a physician does not believe that a particular disease exists, then it will not be given consideration when making a differential diagnosis, and the patient may then go untreated. This is in line with the ancient medical principle that proper diagnosis must precede proper treatment. Or, if for some external reason the physician recognizes the disorder, but feels obligated to use another name, other problems arise, e.g., impaired communication with others regarding exactly what is going on with the patient, and hence improper treatment. This is what is occurring at this point with the parental alienation syndrome, a disorder whose existence has compelling verification. 

In this article I discuss the reasons for denial of the PAS and the ways in which such denial harms families. Particular emphasis will be given to the ways in which this denial harms women, although I will certainly comment on the ways in which the denial harms their husbands and children. In the past, denial of the PAS has caused men much grief. Such denial is now causing women similar grief.

Since the 1970s, we have witnessed a burgeoning of child-custody disputes unparalleled in history. This increase has primarily been the result of two recent developments in the realm of child-custody litigation, namely, the replacement of the tender-years presumption with the best-interests-of-the-child presumption and the increasing popularity of the joint-custodial concept. Under the tender-years presumption, the assumption was made that mothers, by virtue of the fact that they are female, are intrinsically superior to men as child rearers. Accordingly, the father had to provide the court with compelling evidence of serious maternal deficiencies before the court would even consider assigning primary custodial status to the father. Under its replacement, the best-interests-of-the-child presumption, the courts were instructed to ignore gender when adjudicating child-custody disputes and evaluate only parenting capacity, especially factors that related to the best interests of the child. This change resulted in a burgeoning of custody litigation as fathers found themselves with a greater opportunity to gain primary custodial status. Soon thereafter the joint-custodial concept came into vogue, eroding even further the time that custodial mothers were given with their children. Again, this change also brought about an increase and intensification of child-custody litigation.

The Parental Alienation Syndrome

In association with this burgeoning of child-custody litigation, we have witnessed a dramatic increase in the frequency of a disorder rarely seen previously, a disorder that I refer to as the parental alienation syndrome (PAS). In this disorder we see not only programming (“brainwashing”) of the child by one parent to denigrate the other parent, but self-created contributions by the child in support of the alienating parent’s campaign of denigration against the alienated parent. Because of the child’s contribution, I did not consider the terms brainwashing, programming, or other equivalent words to be applicable. Accordingly, in 1985, I introduced the term parental alienation syndrome to cover the combination of these two contributing factors (Gardner, 1985, 1987a). In accordance with this use of the term I suggest this definition of the parental alienation syndrome:

The parental alienation syndrome (PAS) is a disorder that arises primarily in the context of child-custody disputes. Its primary manifestation is the child’s campaign of denigration against a good, loving parent, a campaign that has no justification. It results from the combination of a programming (brainwashing) parent’s indoctrinations and the child’s own contributions to the vilification of the target parent. When true parental abuse and/or neglect is present the child’s animosity may be justified, and so the parental alienation syndrome diagnosis is not applicable.


The alienating parent’s primary purpose for indoctrinating into the children a campaign of denigration against the target parent is to gain leverage in the court of law. The child’s alienation has less to do with bona fide animosity or even hatred of the alienated parent, but more to do with the fear that if such acrimony is not exhibited, the alienating parent will reject the child.

These are the primary symptomatic manifestations of the parental alienation syndrome:

1. A campaign of denigration

2. Weak, absurd, or frivolous rationalizations for the deprecation

3. Lack of ambivalence

4. The “independent-thinker” phenomenon

5. Reflexive support of the alienating parent in the parental conflict

6. Absence of guilt over cruelty to and/or exploitation of the alienated parent

7. The presence of borrowed scenarios

8. Spread of the animosity to the friends and/or extended family of the alienated parent

There are three types of parental alienation syndrome: mild, moderate, and severe. It goes beyond the purposes of this article to describe in full detail the differences between these three types. At this point only a brief summary is warranted. In the mild type, the alienation is relatively superficial, the children basically cooperate with visitation, but are intermittently critical and disgruntled with the victimized parent. In the moderate type, the alienation is more formidable, the children are more disruptive and disrespectful, and the campaign of denigration may be almost continual. In the severe type, visitation may be impossible so hostile are the children, hostile even to the point of being physically violent toward the allegedly hated parent. Other forms of acting-out may be present, acting-out that is designed to inflict ongoing grief upon the parent who is being visited. In some cases the children’s hostility may reach paranoid levels, e.g., they exhibit delusions of persecution and/or fears that they will be murdered. Each type requires a different psychological and legal approach. Further details about the diagnosis and treatment of the parental alienation syndrome have been described elsewhere (Gardner, 1992, 1998, 2001a).

Mothers as Alienators

In the early 1980s, when I first began seeing the PAS, in about 85% to 90% of the cases the mother was the alienating parent and the father the targeted parent. Fathers were certainly trying to program their children to gain leverage in the custody dispute; however, they were less likely to be successful. This related to the fact that the children were generally more closely bonded with their mothers. Recognizing this, I generally recommended the mother to be designated the primary custodial parent, even though she might have been a PAS indoctrinator. It was only in the severe cases (about 10 percent)—when the mother was relentless and/or paranoid and unable to cease and desist from the programming—that I recommended primary custodial status to the father. I was not alone in recognizing this gender disparity, which was confirmed during that period by others. In my experience, the time frame during which mothers were the primary alienators was from the early 1980s (when the disorder first appeared) to the mid-to-late 1990s (when fathers became increasingly active as PAS indoctrinators). The largest study confirming the preponderance of mothers as PAS alienators during the 1980s was that of Clawar and Rivlin (1991).

During this early period, it was quite common for mothers, with the full support of their attorneys, to not only deny that they were PAS programmers, but even went further and denied that the PAS existed. And this denial was especially common in courts of law where their attorneys would argue that there was no such thing as a PAS, and therefore, their clients could not be suffering with a disorder that does not exist. In many cases, neither the mothers nor their attorneys could deny that the children were alienated, but would claim that the alienation was the result of abuse and/or neglect to which the children were subjected by their fathers. Under such circumstances, confusion prevailed and “the waters were muddied,” especially in the courtroom. The PAS diagnosis demands the identification of the specific alienator. Other sources of abuse and/or neglect do not produce this particular constellation of symptoms and do not focus so clearly on a specific alienator. In this more confused environment, the mother’s diagnosis as a PAS programmer might never come to the attention of the court—especially if the lawyer was able to convince the court that there was no such thing as a parental alienation syndrome.

“PAS is Not a Syndrome”

Often, the mother’s lawyer would argue that PAS was not a syndrome, with the implication that it does not exist. A syndrome, by medical definition, is a cluster of symptoms, occurring together, that characterize a specific disease. The symptoms, although seemingly disparate, warrant being grouped together because of a common etiology or basic underlying cause. Furthermore, there is a consistency with regard to such a cluster in that most (if not all) of the symptoms appear together.

Accordingly, there is a kind of purity that a syndrome has that may not be seen in other diseases. For example, a person suffering with pneumococcal pneumonia may have chest pain, cough, purulent sputum, and fever. However, the individual may still have the disease without all these symptoms manifesting themselves. A syndrome is more “pure” because most (if not all) of the symptoms in the cluster predictably manifest themselves. An example would be Down’s Syndrome, which includes a host of seemingly disparate symptoms that do not appear to have a common link. These include mental retardation, mongoloid-type facial expression, drooping lips, slanting eyes, short fifth finger, and atypical creases in the palms of the hands. There is a consistency here in that the people who suffer with Down’s Syndrome often look very much alike and typically exhibit all these symptoms. The common etiology of these disparate symptoms relates to a specific chromosomal abnormality. It is this genetic factor that is responsible for linking together these seemingly disparate symptoms. There is then a primary, basic cause of Down’s Syndrome: a genetic abnormality.

Similarly, the PAS is characterized by a cluster of symptoms that usually appear together in the child, especially in the moderate and severe types. Typically, children who suffer with PAS will exhibit most (if not all) of the eight symptoms described above. This is almost uniformly the case for the moderate and severe types. However, in the mild cases one might not see all eight symptoms. When mild cases progress to moderate or severe, it is highly likely that most (if not all) of the symptoms will be present. This consistency results in PAS children resembling one another. It is because of these considerations that the PAS is a relatively “pure” diagnosis that can easily be made. Due to this purity the PAS lends itself well to research studies, because the population to be studied can easily be identified. Furthermore, I believe that this purity will be verified by interrater reliability studies. As is true of other syndromes, there is an underlying cause: programming by an alienating parent in conjunction with additional contributions by the programmed child. It is for these reasons that PAS is indeed a syndrome, and it is a syndrome by the best medical definition of the term.

“PAS Does Not Exist Because It Is Not in DSM-IV”

Commonly, the mother’s attorneys would argue that PAS does not exist because it is not in DSM-IV (1994). The DSM committees justifiably are quite conservative with regard to the inclusion of newly described clinical phenomena and require many years of research and publications before considering inclusion of a disorder. This is as it should be. Lawyers involved in child-custody disputes see it repeatedly. Mental health professionals involved in such disputes are continually involved with such families. They may not wish to recognize it. They may refer to PAS by another name (like “parental alienation”) (Gardner, 2002a). But that does not preclude its existence. A tree exists as a tree regardless of the reactions of those looking at it. A tree still exists even though some might give it another name. If a dictionary selectively decides to omit the word tree from its compilation of words, that does not mean that the tree does not exist. It only means that the people who wrote that book decided not to include that particular word. Similarly, for someone to look at a tree and say that the tree does not exist does not cause the tree to evaporate. It only indicates that the viewer, for whatever reason, does not wish to see what is right in front of him (her).

DSM-IV was published in 1994. In the early 1990s, when DSM committees were meeting to consider the inclusion of additional disorders, there were too few articles on the PAS in the literature to warrant its submission for consideration. That is no longer the case. It is my understanding that committees will begin to meet for DSM-V in 2003. At this point, DSM-V is scheduled for publication in 2010. Considering the fact that there are now more than 135 articles on the PAS in peer-review journals, it is highly likely that by that time there will be many more. Furthermore, considering the fact that there are now more than 65 rulings in which courts have recognized the PAS, it is probable that there will be even more such rulings by the time the committees meet. These lists are being continually updated and can be found on my website (It is important to note that DSM-IV does not frivolously accept every new proposal. Their requirements are quite stringent, and justifiably so. Gille de la Tourette first described his syndrome in 1885. It was not until 1980, 95 years later, that the disorder found its way into the DSM. It is important to note that at that point, “Tourette’s Syndrome” became Tourette’s Disorder. Asperger first described his syndrome in 1957. It was not until 1994 (37 years later) that it was accepted into DSM-IV and “Asperger’s Syndrome” became Asperger’s Disorder.

DSM-IV states specifically that all disorders contained in the volume are syndromes, and they would not be there if they were not syndromes. Once accepted the name syndrome becomes changed to disorder. However, this is not automatically the pattern for nonpsychiatric disorders. Often the term syndrome becomes locked into the name and becomes so well known that changing the word syndrome to disorder may seem awkward. For example, Down’s syndrome, although well recognized, has never become Down’s disorder. Similarly, AIDS (Autoimmune Deficiency Syndrome) is a well-recognized disease, but still retains the syndrome term.

“Believe the Children”

Lawyers for the mothers would often say to the judge, “Your Honor, why don’t we really listen to what these children are saying. If you don’t feel comfortable putting them on the witness stand, then bring them into your chambers. They will tell you how they feel. Let’s respect their opinions.” Judges not familiar with the PAS might be taken in by these children, and actually believe that they were subjected to the terrible indignities that they described. As far back as 1987 I wrote an article advising judges about this problem and providing them with guidelines for interviewing these children (Gardner, 1987b). Although there are certainly judges who are now more knowledgeable about the PAS than in the late 1980s, judges still play an important role in the etiology and promulgation of the PAS, especially with regard to their failure to impose reasonable sanctions on PAS indoctrinating parents. Elsewhere (Gardner, submitted for publication), I have elaborated on this problem. The believe-the-children philosophy was—and still is—espoused by therapists ignorant of the PAS. Many therapists sanctimoniously profess that they really listen to children (as opposed to the rest of us who presumably do not). They profess that they really respect what children want (with the implication that the rest of us do not). What they are basically doing is contributing to pathological empowerment, which is a central factor in the development and perpetuation of the PAS (Gardner, 2002c). Again, it is beyond the purposes of this article to describe therapists’ role in the development and perpetuation of the PAS. PAS indoctrinators know well that they can rely upon most therapists to empower children’s PAS symptomatology, and that they are readily duped into joining the PAS indoctrinator’s parade of enablers and supporters. Such therapists are often brought into the courtroom to support the mother and her lawyer’s denial of the existence of the PAS and to encourage the court to “really listen” to the children.

“Those Who Make the PAS Diagnosis Are Sexist”

Because mothers were the primary alienators during this early period, PAS was viewed as being intrinsically biased against women. And I, as the person who first wrote on the phenomenon, was viewed as being biased against women and as being “sexist.” The facts are that during this time frame women were the primary alienators. Labeling those who diagnose PAS as sexist is the equivalent of saying that a doctor is biased against women if he claims that more women suffer with breast cancer than men. And the sexist claim has also been brought into courts of law. Fear of being labeled “sexist” has been one factor in many evaluators’ eschewing the PAS diagnosis.

Denial of the PAS Has Caused Permanent Alienation

The denial of PAS has caused many men to suffer formidable psychological suffering. The lawyers of women who have been PAS indoctrinators have convinced courts that PAS does not exist, and therefore the children’s animosity against their fathers is justified. The fact that women are increasingly suffering as target parents gives these men little solace, because many of them have lost their children permanently. In my recent follow-up of 99 PAS children, I provide compelling confirmation that the denial of PAS by courts has resulted in permanent estrangement in the vast majority of cases (Gardner, 2001c).

Fathers as Alienators and Mothers as Target Parents

In the last few years, starting in the late 1990s, there has been a gender shift. Fathers, with increasing frequency, are also indoctrinating PAS into their children (Gardner, 2001b). At this point, my own extensive experiences with PAS families have led me to the conclusion that the ratio is now 50/50, with fathers being as likely as mothers to indoctrinate children into a PAS. And colleagues of mine in various parts of the country are reporting a similar phenomenon.

Why this shift? One probable explanation relates to the fact that fathers are increasingly enjoying expanded visitation time with their children in association with the increasing popularity of shared parenting programs. The more time a programming father has with his children, the more time he has to program them if he is inclined to do so. Another factor operative here probably relates to the fact that with increasing recognition of the PAS, fathers (some of whom have read my books) have learned about the disorder and have decided to use the same PAS indoctrinational maneuvers utilized by women. It is probable that other factors are operative as well in the gender shift, but these are the two best explanations that I have at this point.

With the gender shift of PAS indoctrinators, there has consequently been a gender shift in PAS target parents. Mothers are increasingly finding themselves victims (I use the word without hesitation) of their husbands’ PAS indoctrinations of their children. Such mothers know well that PAS exists. They read my books and say, as have the father victims before them, “It’s almost as if you’ve lived in my house. You’re describing exactly what has been going on.” These mothers find themselves helpless. They cannot get help from therapists who are still mouthing the old mantras, “PAS is just Gardner’s theory,” “PAS doesn’t exist because it’s not in DSM-IV,” “PAS is not a syndrome.” Their lawyers, too, will tell them, “PAS might exist, but the court will not recognize it. I can’t use the word syndrome in the courtroom. It’s the ‘big S’ word.” Worse yet, many leaders in the Women’s Rights movement are reflexively chanting the same incantations, thereby abandoning the women whose cause they profess to espouse. These mantras have become deeply embedded in the brain circuitry of most of the people the alienated women are looking to for help—therapists, lawyers, guardians ad litems, and judges. And these groups cannot even turn to the Women’s Rights groups because they have long ago stridently taken the position that PAS does not exist, that PAS is not a syndrome, etc., etc. We see here how those who deny the existence of PAS are adding formidably to the grief of women. Women’s past denial and discrediting of PAS has now come back to haunt them. Women are now being injured by their own weapons, or, as the old saying goes, they are being “hoist by their own pitards.”

The Relationship Between PAS and Bona Fide Abuse

In recent years, with increasing frequency, mental health and legal professionals have been seeing cases in which one parent (more often the father) has accused the other parent (more often the mother) of inducing a PAS in the children. In response, the responding parent (usually the mother) accuses the other parent (usually the father) of abusing and neglecting the children. In short, then, the children’s alienation against the father is considered by him to be the result of the mother’s PAS programming, and the mother considers their alienation to be the result of the father’s abuse/neglect. I have no doubt that some abusing/neglectful parents are using the PAS explanation to explain the children’s alienation as a cover-up and diversionary maneuver designed to deflect exposure of their abuse/neglect. However, there is no question that some PAS-inducing mothers are using the argument that it is the father’s abuse/neglect that is causing the children’s campaign of denigration, and thereby denying any programming whatsoever. In short, such programming mothers are basically saying: “He’s getting what he deserves, and I’m not programming them.” Elsewhere (Gardner, 1998, 1999) I have described criteria for differentiating between PAS and bona fide abuse/neglect.

Of relevance to this article is the common phenomenon in which genuinely abusing husbands use the argument that the children’s alienation has nothing to do with their abuse, but is the result of the mother’s PAS indoctrinations. Such mothers will invoke the argument that this deceitful maneuver is not going to work, especially because there is no such thing as the PAS. This is a handy argument, and they will easily find legal and mental health professionals who will support them in this denial. Although I am sympathetic with these falsely accused women, their contributions to the denial of the existence of the PAS is not serving well other women who are indeed PAS victims. And this factor has been operative in increasing the grief suffered by women who are indeed PAS target parents. Their PAS indoctrinating husbands are now waving the same “PAS-doesn’t-exist” flags that PAS indoctrinating women were waving in the 1980s and early 1990s. Wives who were being falsely accused by their husbands of being PAS indoctrinators would have done much better to agree that PAS does exist, but they themselves are not indoctrinators, that the children’s symptoms are not those of PAS children, but symptoms of children who have been genuinely abused.

The Effects on Children

The denial of PAS in the early period resulted in many children living primarily with their programming mothers, with the result that they became permanently estranged from loving fathers. They were deprived, therefore, of all the benefits that could have come from their father. There is no question that follow-up studies of these children will reveal significant psychopathological residua from these early experiences. One cannot grow up and be a healthy person if, throughout the course of one’s childhood, one was taught that a previously loving and dedicated father was really loathsome and vicious. This inevitably will affect their relationships with other males—dates, boyfriends, teachers, employers, friends, etc. In the more recent phase, with men as increasingly frequent indoctrinators, we will have a similar group of children growing up believing that their previously loving mothers were vile, loathsome, and noxious. Similarly, one cannot become a healthy person believing that the primary maternal figure has been and still is a despicable and loathsome human being. Such a distortion of reality cannot but affect future relationships with other females—dates, employers, friends, etc.

The Solution

The first step in the treatment of denial is the acceptance of reality. The first step, then, must be the recognition that PAS exists, even if there are thousands of people, both husbands and wives, who claim that it does not. PAS exists, even though there are thousands of lawyers who will claim that it does not. PAS exists even though there are thousands of mental health professionals who claim that it does not. It exists even though there are Courts of Appeal who rule that it does not exist. It exists even if all nine members of the U.S. Supreme Court were to rule that it does not exist. It exists even though it is not in DSM-IV, and it will continue to exist even if the DSM-V committees choose not to include it. The first step, then, must be to recognize and stop denying its existence. Mental health professionals should be free to diagnose the disorder when it is present, and not have to worry about whether the diagnosis will be accepted in a court of law. They should recognize that in the adversarial system there will always be attorneys who will try to discredit whatever they say, because this is what they have learned to do in law school. Mental health professionals should not worry about whether they are in the minority or the majority with regard to the diagnosis. Rather, they should only be concerned with honesty and reality. They should not be concerned with those who may irrationally label them sexist or biased against either men or women if they make a diagnosis of PAS. Whenever some external considerations operate or affect one’s diagnostic objectivity, there is bound to be some contamination and bias. Worse, it will inevitably not serve well the patients whom one is evaluating and treating. If this point is reached, it is likely that the frequency of PAS will be reduced because would-be indoctrinators will recognize that they will not have available mental health professionals to help them manipulate the legal system.

Concluding Comments

Denial of PAS has caused significant psychological suffering to many men, many women, and many children. And its denial has only added to the burden of families in which this disorder has been present. Furthermore, the denial of PAS will lessen the likelihood of ultimate inclusion in DSM-V. And this will have a negative impact on all those who are afflicted with this disorder. The more PAS is recognized, the greater the number of research articles will be written. This will, in turn, enhance the receptivity of the DSM-V committees. The more courts of law that have accepted PAS, the greater the likelihood that the DSM-V committee will recognize the disorder. Mental health professionals, especially, should take this factor into consideration when they eschew the diagnosis.

In closing, I quote from the concluding comments in my follow-up study of 99 PAS children:

When I embarked upon this study, I expected that most of the PAS children would continue to be alienated from the target parent in situations in which the court neither transferred custody to the target parent nor reduced the alienating parent’s access to the children. What I did not expect was the high rate of completely destroyed relationships and the enormous grief suffered by the alienated parents. I expected the average follow-up conversation to last five minutes, during which I would get the basic data. It turned out that most conversations lasted between 15 and 30 minutes, because the parents needed me at that point for some kind of ventilation of their painful feelings. I did not expect such a degree of grief. However, on looking back upon the study, I should not have been surprised. I consider losing a child because of PAS to be more painful and psychologically devastating than the death of a child. A child’s death is final and there is absolutely no hope for reconciliation. Most bereaved parents ultimately resign themselves to this painful reality. The PAS child is still alive and may even be in the vicinity. Yet, there is little if any contact, when contact is feasible. Therefore, resignation to the loss is much more difficult for the PAS alienated parent than for the parent whose child has died. For some alienated parents the continuous heartache is similar to living death.


The American Psychiatric Association (1994), Diagnostic and Statistical Manual of Mental Disorders, Fourth Edition (DSM-IV). Washington, D.C.:American Psychiatric Association.

Clawar, W. S. & Rivlin, B. V. (1991). Children Held Hostage: Dealing with Programmed and Brainwashed Children. Chicago: American Bar Association.

Gardner, R. A. (1985). Recent trends in divorce and custody litigation. Academy Forum, 29(2),3-7.

Gardner, R. A. (1987a). Child custody. In J. D. Noshpitz (ed.) Basic Handbook of Child Psychiatry (pp. 637-646). New York: Basic Books.

Gardner, R. A. (1987b). Judges interviewing children in custody/visitation litigation. New Jersey Family Lawyer 7(2), 153ff

Gardner, R. A. (1992). The Parental Alienation Syndrome: A Guide for Mental Health Professionals. Cresskill, New Jersey: Creative Therapeutics, Inc.

Gardner, R. A. (1998). The Parental Alienation Syndrome: Second Edition. Cresskill, New Jersey: Creative Therapeutics, Inc.

Gardner, R. A. (1999). Differentiating between PAS and bona fide abuse/neglect. The American Journal of Family Therapy, 27(3), 195-212.

Gardner, R. A. (2001a). Therapeutic Interventions for Children with Parental Alienation Syndrome. Cresskill, New Jersey: Creative Therapeutics, Inc.

Gardner, R. A. (2001b). The recent gender shift in PAS indoctrinators. News for Women in Psychiatry, 19(4),11-13.

Gardner, R. A. (2001c). Should courts order PAS children to visit/reside with the alienated parent? A follow-up study. The American Journal of Forensic Psychology, 19(3),60-106.

Gardner, R. A. (2002a). Parental alienation syndrome vs. parental alienation: which diagnosis should evaluators use in child-custody litigation? The American Journal of Family Therapy, 30(2),101-123.

Gardner, R. A. (2002b). Does DSM-IV have equivalents for the parental alienation syndrome (PAS) diagnosis? The American Journal of Family therapy (in press)

Gardner, R. A. (2002c). The empowerment of children in the development of the parental alienation syndrome. The American Journal of Forensic Psychology, 20(1) (in press)

Gardner, R. A. The judiciary’s role in the etiology, symptom development, and treatment of the parental alienation syndrome (PAS). (Submitted for publication), Articles in Peer-reviewed Journals and Published Books on the Parental Alienation Syndrome (PAS).

_______, Testimony Concerning the Parental Alienation Syndrome Has Been Admitted in Courts of Law in Many States and Countries.

Categories: Journals

The Parental Alienation Syndrome:An Analysis of Sixteen Selected Cases, Dunne & Hedrick

JOURNAL OF DIVORCE & REMARRIAGE, Vol. 21, p 21-38 1994

The Parental Alienation Syndrome:
An Analysis of Sixteen Selected Cases

John Dunne
Marsha Hedrick

ABSTRACT. This study analyzed sixteen cases which appeared to meet Dr. Richard Gardner’s criteria for parental alienation syndrome as set forth in his 1987 book. These cases showed a wide diversity of characteristics but Gardner’s criteria were useful in differentiating these cases from other post-divorce difficulties. Traditional interventions were ineffective in altering the alienation.

Gardner (1985) has described cases of intense rejection of a parent by children after divorce which he referred to as “parental alienation syndrome” (PAS). He defined this syndrome as a disturbance occurring in children who are preoccupied with depreciation and criticism of a parent and denigration that is unjustified and/or exaggerated (Gardner, 1987). He describes these children as “obsessed with hatred of a parent.”

The “parental alienation syndrome” has rapidly become a focus of controversy within the mental health and the legal profession. It has been raised, as well as attacked, in cases involving allegations of domestic violence, parental substance abuse, and child sexual abuse, often strongly polarizing various mental health professionals involved in the cases. Advocacy groups for mothers, fathers, and sexual abuse victims have often been recruited into the conflict.

Very little is described in the literature about children who reject parents following marital separation. Jacobs (1988)describes a case in which five children rejected their father, apparently in response to their mother’s extreme narcissistic rage. Wallerstein (1984) noted one child at the ten year follow-up, who rejected her mother, with whom she was living, after her father’s attempt to change custody failed. Fidler (1988) also noted one case of a child who refused to see the noncustodial parent among the sample of 76 children referred to a family court clinic.

More common in the literature is the failure to mention a child’s rejection of a parent as one of the outcomes of divorce. Pearson and Thoennes (1990) noted a relatively high frequency of no or sporadic overnight visits with a non-residential parent. In 40% of the maternal sole custody and 30% of the paternal sole custody, the children had no overnight visits with a non-residential parent. In joint legal custody, 7% of the children living with their mothers and 20% of the children living with their fathers reported no overnights with the other parent. Although this is a relatively high frequency, the authors made no mention of the children’s attitudes about their parents or the reason for no visits. Kalter et al. (1989) did not report any cases of the child rejecting a parent in their sample of 56 recruited pairs of children and mothers. Similarly, Oppenheimer et al. (1990) noted no cases in their sample of 46 elementary aged children, all living with their mothers, who rejected either parent. Review articles by Zaslow (1988) and by Heatherington et at. (1989) make no reference to parent alienation or to children rejecting a parent as an outcome following divorce.

Rather than specifically identifying children’s rejection of a parent, several authors made reference to difficulties arising when a child aligns with a parent or attempts to step into the role of protecting a vulnerable parent. For example, Johnston et at. (1989) noted that large numbers of children attempt to align with one or both angry parents which simultaneously helps the child feel more important and more vulnerable. They indicated that the “typical” response of an older child was to be negative toward the other parent to some degree and to perhaps reject that parent or refuse to visit. In another paper, Johnston and her colleagues (Johnston et al. 1987) noted a tendency of children to become protective toward a fragile parent, the frequency of role reversals, and a tendency to take responsibility in the parental disputes. Jacobs (1988) and Wallerstein (1985) refer to the intense rage of the narcissistically injured parent as being critical in the child’s attitudes about the other parent. Wallerstein also refers to the pathological dependence of a parent on a child to protect against feelings of loss as being important in the child’s emerging need to protect that parent from intolerable feelings. Oppenheimer and colleagues (1990) concluded that the child’s perceptions of parental attitudes and their own beliefs about the divorce have a significant influence on their post-separation adjustment, presumably also including the degree of hostility they felt toward one or both parents.

The authors have been unable to locate any studies systematically analyzing the children and their families when one or more of the children in the family have rejected a parent after divorce. Such an analysis would be a necessary first step in attempting to validate Gardner’s “parental alienation syndrome” and his hypothesis about etiology. This study was undertaken to explore characteristics of cases which appeared to meet Gardner’s criteria, to search for commonalities among the cases, and to alert mental health professional to this infrequent but serious outcome in children after divorce.

All cases presented here were referred to one or both of the authors for forensic evaluation or treatment of a seemingly intractable situation, Cases were selected for the study on the basis of at least one child in the family having intensely rejected one of the parents on the basis of trivial or unsubstantiated accusations, apparently meeting Gardner’s criteria for “parental alienation syndrome,” There was no attempt to match these cases with a control group of children whose parents had also separated and/or divorced.


The sixteen cases in this study were taken from the caseloads of basis that they met the majority of the criteria set forth by Gardner, (1985, 1987), in his description of the parental alienation syndrome. Those criteria are as follows:

  1. Child is preoccupied with depreciation and criticism of the parent that is unjustified and/or exaggerated.
  2. Conscious, subconscious, and unconscious factors within the alienating parent contribute to the child’s alienation from the other.
  3. Denigration of the parent has the quality of a litany, a rehearsed quality. There is phraseology not usually used by the child.
  4. Child justifies the alienation with memories of minor altercations experienced in die relationship with the parent which are trivial and which most children would have forgotten. When asked, the children are unable to give more compelling reasons.
  5. The alienating parent will concur with the children and support their belief that these reasons justify the alienation.
  6. Hatred of the parent is most incense when the alienating parent and the child are in the presence of the alienated parent. However, when the child is alone with the alienated parent, the child may exhibit hatred, neutrality, or expressions of affection.
  7. If the child begins to enjoy him/herself with the alienated parent, there may be episodes of “stiffening up” and resuming withdrawal and animosity, as though they have done something wrong. Alternatively, the child may ask the alienated parent not to reveal his/her affection to the other parent.
  8. The degree of animosity in the child’s behavior and verbalizations may vary with the degree of proximity to the alienating parent.
  9. Hatred of the parent often extends to include die alienated parent’s extended family, with even less justification by the child.
  10. The alienating parent is generally unconcerned with the psychological effects on the child of the rejection of parent and extended family.
  11. The child’s hatred of the alienated parent is often impervious to evidence which contradicts his/her position.
  12. The child’s position seemingly lacks ambivalence. The alienated parent is “all bad,” the alienating parent is “all good.”
  13. The child is apt to exhibit a guiltless disregard for the feelings of the alienated parent.
  14. The child fears the loss of the love of the alienating parent.

By choosing cases which met the majority of these criteria, the authors were selecting for situations which embodied severe parental alienation, rather than the more common and more moderate instances of loyalty conflicts which are widely evident in the children of conflictual divorcing parents.

In an effort to better understand the sub-population of divorcing families who manifest an alienation of one parent, these cases were analyzed and data obtained regarding the following variables:

  1. length of the relationship or marriage prior to separation.
  2. the age of the children at separation.
  3. the length of time’ between separation and the onset of the alienation.
  4. the number of children in each family constellation who exhibited the dynamic.
  5. the sex of the alienating parent.
  6. the sex of the children.
  7. the effectiveness of various interventions in remedying the alienation.

Case #1

A had just turned six years old when she was referred for treatment by her Guardian Ad Litem. She was an only child from the father’s second marriage and the mother’s first marriage. She attended the first grade at a private school for gifted children and seemed to get along well with peers.

The parents had separated one and a half years prior to the referral for treatment, initially the parents agreed that A would live with her mother and be with her father on alternate weekends from Saturday morning until Sunday evening, as well as holiday and vacation time. However, A almost immediately became resistant to leaving her mother and going with her father. At times the father had to pick her up and carry her to the car kicking and screaming. These difficulties paralleled an increase in the mother’s accusations about the father’s harassment and alcohol abuse. There were several court attempts to increasingly supervise the contacts between the parents and the visitation time with the father. Eventually, each of the parents was ordered into individual therapy, as was A. In addition, a GAL was appointed and a supervisor for the visitations was assigned.

None of these efforts seemed to alter the progressive rejection of the father by A in clinical sessions. She was initially guarded and resistant, her affect flat and joyless. It was reported by the supervisor that during her visits with her father she was relaxed and playful, although she seemed to most enjoy spending time with her father’s live-in girlfriend. However, when it came time to return to her mother, she became quite panicked aid insisted on taking off any makeup or clothes that might indicate that she had had fun at her father’s. When she returned to her mother, she consistently complained about each visit. Her play themes in therapy excluded any reference to men or fathers.

A’s mother was a forty-two year old medical professional who had not worked since A’s birth. She was supported by a large stipend from her ex-husband and devoted all her energies to A. She claimed that A became very upset whenever she talked about the possibility of going back to work and used this as a rationalization for not returning to work. Despite her intense hostility and her many accusations toward the father, the mother confided that she continued to love him and was quite jealous of the father’s new relationship. She insisted that A have nothing to do with the father’s girlfriend and forbade the therapist to talk with the girlfriend. This mother viewed her daughter as unique and special, frequently insisting on special treatment or considerations. She had no insight into her role in alienating her daughter from her father and blamed everything on the father’s aberrant behavior.

The father was a well-paid physician and accomplished outdoorsman who was highly thought of in both his profession and avocation. Although very angered by his ex-wife’s accusations, he tended to respond passively and did not want to challenge her directly At times, however, his anger would erupt during confrontations by her. He saw his ex-wife as obsessed with their daughter and deluded by her own fantasies. He described his daughter as having two personalities, one when she was under the influence of her mother, when she acted like an extension of her mother’s ego, and another when she was with him, a happy and playful child. At one point the father was allowed to take his daughter on an extended vacation where they reportedly had a very good time together. However, difficulties re-emerged immediately upon the daughter returning to her mother’s home.

Two years after the separation and with no progress evident despite treatment for all three individuals, the father agreed to have no further contact with his daughter. This was viewed as preferable to continuing the conflict which appeared to have no resolution for her. He continued to make voluntary contributions to a trust fund for her and sent her letters occasionally, which he hoped she would mad after she became an adult.

Case #2

F was a twelve year old girl and G a ten year old boy at the time of this evaluation. They had been placed together in foster care following their detailed descriptions of sexual and physical abuse by their father and physical abuse by their step-mother, with whom they primarily resided. Despite the children’s statements and wishes, the court did not place them with the mother because of allegations that she had instigated their statements against the father. The children had only supervised contact with both parents during this evaluation.

The mother had initiated the marital separation six years prior and the father had resisted the divorce. Following the separation, the mother made accusations of physical abuse of herself by the father and on the day prior to the commencement of the divorce trial, the mother made allegations of sexual abuse of the children by the father. The trial was postponed and several professionals evaluated the children. Those evaluations substantiated that the daughter had been sexually abused by the mother’s boyfriend’s (now husband’s) son but did not substantiate sexual abuse by the father. The custody of the children was subsequently awarded to the father. A year following the divorce, the mother made another report to CPS alleging physical abuse and possible sexual abuse of the children by the father. After investigation the allegations were dismissed as unsubstantiated. One year later the mother attempted to modify custody but this request was denied. in the same year, approximately three years after the separation, both parents remarried and all four parties were ordered to participate together in an attempt at counseling.

Approximately one year after the counseling, the daughter was interviewed by a CPS worker after she reported to her school that she was afraid to return to her father’s home following a weekend visitation with the mother. After investigation, the case was again closed. Two months later, during a visit with their mother, the children made die statements to neighbors and later to the CPS caseworker which prompted this evaluation with one of the authors.

Psychological testing of the mother produced clinical scares elevated beyond the normal range. The clinical pattern suggested that she was immature, narcissistic, self-indulgent as well as passive-dependent. The testing also suggested that she was likely to be suspicious of the motivations of others, avoidant of deep emotional involvement, angry, argumentative, stubborn, and prone to externalization. Psychological testing of the father was not elevated beyond die normal range. His normal range profile suggested that he was apt to be naive, hopeful, optimistic, and suggestible with a persistent need to be liked by others and a tendency to avoid confrontation and negativity. There was also some evidence of insecurity, feelings of inadequacy, and a tendency to anticipate rejection. Because the allegations involved the father’s current wife, she was also evaluated. She was found to be an exceptionally well-functioning individual.

The father’s childhood history was benign and he enjoyed a good relationship with his parents as an adult. However, the mother’s history included a very disturbed relationship with her own parents and considerable parental dysfunction during her childhood.

At the time of the evaluation, the mother was a fulltime homemaker, with one child front her second marriage at home. She volunteered at an abused women’s shelter and through this activity had a wide circle of friends who offered her considerable support. The father and step-mother were both postal workers who were pursuing educational goals on a part time basis, were active in the schools, and well-regarded by neighbors. They had voluntarily sought counseling for the family several months prior to the allegations because of the degree of conflict between the two households and the effect of that on the children.

Although the children initially made detailed statements about physical and sexual abuse to professionals, during this evaluation their statements were very general and contradictory of earlier statements. Both children exhibited much more affect and energy around statements having to do with the divorce conflict than with abuse, i.e., child support issues and values about living in urban rather than rural areas. Their “memories” of various events appeared to be highly contaminated by their mother’s issues and perceptions.

This evaluation failed to substantiate abuse of the children by the father or the step-mother and implicated the mother in excessively influencing the children’s statements against the father. Following a trial, the judge returned the children to their father’s home. The mother’s contact with the children was temporarily suspended while the children were reinvolved with the therapist with whom they had previously been in counseling. The mother was then asked to initiate gradual contact with the children through the therapist via letters and phone calls. However, after a brief time, the mother moved out of the state and did not follow through with supervised contact. The children have had no contact with their mother for more than one year. Their therapist reports that their overall functioning is much better than prior to the allegations, although both children have difficulty understanding their mother’s failure to maintain contact with them. Their therapist has described the children’s fabrications of abuse as an attempt on their part to consolidate a very tenuous relationship with their mother. She felt it was made clear to the children that acceptance by their mother was contingent upon rejection of the father and they appeared willing to sacrifice a very secure relationship with the father and step-mother in order to resolve the issue of their mother’s commitment to them.

Case #3

This case involved a girl, M. who was two years, six months at the time of the evaluation. There had been a long series of allegations by the mother toward the father beginning in the early months of the pregnancy. The most recent of these allegations was that the father was sexually abusing the child during the limited visits that the child had with the father at the paternal grandparents’ home. CPS had been involved twice and made a preliminary conclusion that sexual abuse was probable based on the child’s statement that “daddy hurt my butt.”

The father was a 24 year old blue-collar worker whose work often necessitated that lie be out of town for three to four months at a time. Both clinical evaluation and psychological testing suggested a somewhat immature, narcissistic, and impulsive young man. He viewed Iris ex-wife as deceitful, unpredictable, and emotionally volatile. Although he had had two DWI’s, he tended to minimize his drinking pattern and deny that Ire had a problem. A detailed psychosexual history was essentially unremarkable. He had dated relatively infrequently and tended to be attracted to women for superficial attributes. His involvement with M’s mother was his first serious relationship. There was no history of sexually inappropriate behavior.

The mother was a 24 year old woman who had worked occasionally as a clerical worker. At the time of the evaluation she lived with her parents, who supplemented the child support payments and funded her protracted legal battle with her ex-husband. The mother’s family was dominated by the maternal grandmother from whom the mother had never emancipated. Psychological testing and clinical interview suggested a person with strong narcissistic, histrionic, and dependent traits. She appeared willing to exploit others without regard to their feelings. She had a long history of avoiding disapproval by deflecting blame to others. The extensive legal file seemed to document her willingness to fabricate data to prevent her daughter from visiting her father.

Many of her allegations had some element of truth but always represented the worst possible interpretation of her ex-husband’s behavior or character. A few months before the allegations about sexual abuse, the mother had called the local police department, and discovered there was an outstanding warrant for the father because he had failed to show for a summons on a DWI. She waited until the father had made arrangements to pick up their daughter for a visit, notified the local police, and arranged to have him arrested as he appeared for the visit.

M had a history of constipation following her visits with her father. Several hours after her return from one visit, and after having played in a wading pool with several other children, M was noticed to have several abrasions on her back. Later that same day, she was described as having a purplish protrusion of her anus at which time M stated that her father “hurt my butt.” Subsequent evaluation by a pediatrician trained in sexual abuse issues was ambiguous. However, a later colposcopic exam of the anus showed multiple angulations, suggestive of repealed anal penetration, but also occurring frequently in children without a history of anal penetration. A thorough psychiatric evaluation of this family concluded that there was evidence of parental alienation syndrome and did not substantiate the likelihood of sexual abuse.

M was referred to an experienced female child therapist. M subsequently revealed in more detail that the father had poked her in the anus with his finger an several occasions when he was in his bedroom at the grandparents’ home. However, M gave a different description on re-evaluation with the original evaluator. She had no signs of sexualized behavior and in all other ways her development was progressing normally. She seemed acutely aware of her mother’s dislike of her father. It was concluded that this case represented parental alienation syndrome.

Case #4

C was a sixteen year old girl, D a twelve year old boy, and E a nine year old girl at the time of the evaluation which occurred a year and a half after the marital separation. All three children were refusing to have any contact with their father and had not seen him for over a year at the time of the evaluation.

Prior to the separation. the children spent extensive time with other caretakers because of their parents’ strenuous work schedules. There was evidence of poor supervision and lack of involvement by both parents during that time. However, all three children had been very attached to their father by all reports. The father initiated the separation after sixteen years of marriage because he had become involved with a woman with whom he worked. The mother was distraught over the separation and experienced a brief episode of psychotic depression characterized by delusions, memory loss, and disorientation. She then precipitously moved the children to another town several hours from the father. The children saw their father for several months after the separation on brief visits. However, when it became apparent that he would not return to the household and was seeing the woman with whom he had become involved, all three children eventually refused to have contact with him.

The mother seemed unable to differentiate the father’s unwillingness to continue their relationship from his desire to continue to parent the children. She repeatedly referred to her husband’s “abandonment of the family” and had conducted a “burial ceremony” during which she and the children symbolically buried the father so that the “new family,” which did not include the father, could move forward.

After repeatedly being frustrated in his attempt to make contact with the children, the father initiated an evaluation through Family Court. At the time of the evaluation, D had gained 80 pounds since the separation and was now 100% over his optimal weight. The mother explained the children’s decision to have no contact with their father as resulting from their being in Catholic schools and therefore intolerant of the idea of divorce. She contended that she had encouraged the children to see their father but to no avail. However, information from neighbors and letters written by her to the father strongly suggested that she was motivated to sever the children’s contact with the father and quite vociferous regarding her animosity towards him in their presence.

Psychological testing suggested that the father relied on denial for dealing with conflict, was somewhat oversensitive in interpersonal relationships, but otherwise outgoing and sociable. There was also the suggestion of some narcissism in his dealings with others. The mother’s psychological testing was invalidated by considerable defensiveness characteristic of individuals who deny psychological problems, are unsophisticated psychologically, and who claim excessive virtue. The testing also suggested that she was apt to be inflexible, unrealistic. and very needful of being seen by others in a positive light.

The evaluation concluded that it was the mother’s inability to differentiate her own needs from those of the children that had led to the children’s alienation from their father. The evaluator recommended that the custody of D and E be immediately and temporarily changed to the father for two months while the mother sought therapy for herself and C. However, the court denied that recommendation but did order visitations to begin immediately for all three children. Only after several months delay did the children begin therapy and brief visits with their father. Following several more months of therapy and contact with the father only during the therapy sessions, D asked to stay over night with his father. The mother reacted with rage, as though D had betrayed her. However, with the support of his counselor and father, 13 was able to follow through on his wish to spend alternate weekends with his father. C, however, continued to refuse to have any contact with her father and E continued to have only brief daytime visits on alternate weekends. The mother found her son’s proactive relationship with his father intolerable and within nine months sent him to live with the father claiming D had become abusive and unmanageable.


In fourteen of the sixteen cases in this study, the mother had primary custody and was the alienating parent. In one case, the non-custodial mother was the alienating parent and in one case, the non-custodial father was the alienating parent.

There were a total of 26 children (14 girls and 12 boys) in these 16 families and 21 of the 26 children appeared to be involved in the alienation dynamic with a parent. Twelve of the alienated children were female and nine were male.

The length of the marriage prior to final separation was tabulated. In two of the cases, there was no marriage and in three more cases the marriages lasted less than six months. One marriage ended after four years, six had survived between five and ten years, and four had lasted between eleven and fifteen years.

The ages of the alienated children at the time of parental separation ranged from in utero (four cases) to fourteen years of age and appeared evenly distributed across age brackets.

The cases were analyzed to determine the approximate amount of time between the separation and the onset of alienation, as determined by the clinician retrospectively. In five of the cases, onset appeared to be coincident with the separation. In two of the cases, alienation appeared within six months after separation. In four more cases, the alienation became apparent from one to two years after separation. In the final four cases, the alienation occurred between three and six years after separation.

In looking at interventions to deal with the alienation from a parent, a wide range of both legal and clinical processes were identified. In three of the cases, a change of custody away from the alienating parent or a strict limitation of that parent’s contact with the child(ren) was implemented by the court system. In all three cases, this was successful in eradicating the alienation. There were no cases in which a change of custody occurred but the alienation continued. In the other thirteen cases, various interventions were tried, ranging from therapy for each of the parents individually, therapy for the parents together, therapy for the children with the alienated parent, therapy fur the children with the alienating parent, and the assignment of a Guardian Ad Litem to the case. In two of these cases, the children were evaluated as having experienced “some” or “minimal” improvement in their relationship with the alienated parent. In the other eleven cases, there was no improvement and in two of these cases, the alienation was evaluated as “worse” after these interventions.


These cases exemplify the wide diversity and complex nature of the “parental alienation syndrome” as it is played out in parental access disputes. In contrast to Gardner’s (1985, 1987, 1992) anecdotal description of cases, this study attempted to analyze the salient characteristics of selected cases meeting Gardner’s criteria for parental alienation. These cases suggest that the syndrome can occur without reference to the length of the relationship prior to separation, can occur immediately following separation, or not until many years after the divorce. It can occur in very young children as well as with teens who have previously enjoyed a lengthy and positive post-divorce relationship with the alienated parent. It can involve all children in the family constellation or only one of the children. The alienating parent is most often the custodial mother but alienation by non-custodial fathers or mothers was also observed.

Then was a wide range in the severity of symptoms of PAS. It may be true that some elements of PAS are present to some degree in a majority of divorcing families. Our findings are consistent with those of Johnston et al. (1989) in that all of our cases were entrenched in intense post-divorce conflicts. As such they may represent a severe form of a psychological response common in the children of divorcing parents and may not deserve to be classified as a distinct syndrome,

Jacobs (1988) and Wallerstein (1985) refer to narcissistic injury as the motivating force for the alienating parent. Jacobs (1988) also suggests a form of “sibling rivalry” between the divorcing parents for the control and love of the child and Wallerstein (1985) suggests a pathological dependence of a parent on the child to protect against feelings of loss as another underlying dynamic. This is supported by the observations in this study that all of the alienating parents experience intense dysphoric feelings which they blamed on their former spouses. Predominantly the alienating parents experienced intense narcissistic injuries. However, issues of “sibling rivalry” and pathological defense against feelings of loss were also present in at least some of the alienating parents. In some cases, more than one motivating factor appeared to be involved. It should be underscored, however, that these motivations are often strikingly out of the consciousness of the alienating parent, many of whom were adept at coloring their motivations and behaviors in socially acceptable ways to themselves as well as to professionals.

Contrary to what might easily be assumed by professionals, this study suggests that PAS does not necessarily signify dysfunction in either the alienated parent or in the relationship between that parent and child. PAS appears to be primarily a Function of the pathology of the alienating parent and that parent’s relationship with the children. Children are apt to be susceptible to alienation when they perceive that the alienating parent’s emotional survival or the survival of their relationship with the alienating parent is dependent upon the child’s rejection of the other parent. This is consistent with the finding of Johnston et al. (1987) in which they noted a tendency for children to be protective toward a fragile parent when the parents were entrenched in disputes over custody and access.

Efforts to evaluate these issues based on complaints by the child or one parent are generally fruitless. Assessment of the entire family dynamics, with an awareness of Gardner’s descriptions of parental alienation, appears useful in understanding these complaints and differentiating them from alienation resulting from cases of abuse or other deficits in the alienated parent and his/her relationship with the children.

This study also suggests that traditional therapies and interventions are not successful in rehabilitating children affected by this syndrome. Although the courts have been reluctant to take drastic action, especially when this is contrary to a child’s explicit wishes, in this study only a change in custody to tile alienated parent was successful in remedying tile alienation. It should be noted, however, that in two of the cases in this study in which the court was willing to take this step, and one case hi which a change of custody occurred voluntarily, the children eventually had little contact with the alienating parent. This suggests that the PAS dynamic may be so toxic that a relationship with both parents may not be possible, or in the child’s best interests, in cases of severe alienation. Each case must be evaluated on its own merits and the identification of a parental alienation syndrome is not sufficient, in and of itself, to justify changes in custody. Full evaluation of a child’s situation and relative parental strengths and weaknesses may identify instances when it is in the best interest of tile child to remain with the alienating parent and to have little or no contact with the alienated parent in order to reduce the effects of continued conflict on the child.

Although the “parental alienation syndrome” was only first described in 1985 (Gardner, 1985), the question arises as to whether PAS has always been evident in the divorcing population, but unrecognized, or whether it is a recent phenomenon, perhaps increasing in prevalence. Although this study did not address this question, it is possible that both may be true. With social changes creating parity between parents in the eyes of the court, a mother’s traditional role with her children may be undermined. This may be perceived by the mother as a considerable psychological threat which can only be dealt with by developing a pathological alliance with the child.

Professionals who work with the divorcing population, either as therapists, or evaluators, need to be aware of the symptoms of PAS and the difficulties that these cases present for the families and for the court system. A failure to appropriately identify and intervene in the early stages of these cases may result in the alienating parent being given professional support for his/her position, reinforcing the child’s need to maintain or expand complaints about the alienated parent. This has the capacity to more firmly entrench the syndrome and to enhance the severity of the dynamics.

Further study is necessary to assess the prevalence, the range of severity, the effect on development, and the longterm outcome for children who remain alienated from one of their parents. As this study suggests, very little is known about what interventions would allow a child to have functional relationships with both parents in such highly polarized cases. It is the obvious hope that this study would prompt others to systematically evaluate series of cases, perhaps clarifying the etiology and evolution of the syndrome. Moreover, larger populations of divorcing families need to be examined for the prevalence of partial or complete alienation of a child from a parent. Retrospective studies of adults who have remained alienated throughout their childhood development may also be useful in understanding this syndrome and its consequences.


1. Fidler, B.J., Ph.D., & E.B. Saunders, Ed D. (1988). Children’s adjustment during custody/access disputes: Relation to custody arrangements, gender and age of child. Canadian Journal of Psychiatry, 33(6), 517-523.

2. Gardner, R.A. (1985). Recent trends in divorce and custody litigation. Academy Forum, 29 (2), 3-7.

3. Gardner, R.A. (1987). The parental alienation syndrome and the differentiation between fabricated and genuine sexual abuse. Creative Therapeutics, Cresskill, N.J.

4. Heatherington, M., M. Stanley-Hagan. & E.R. Anderson (1989). Marital transitions: A child’s perspective. American Psychologist, 44(2), 303-312

5. Jacobs, J.E., M.D. (1988). Euripides medea: A psychodynamic model of severe divorce pathology. American Journal of Psychotherapy, 42(2), 308-319.

6. Johnston, J.R., R. Gonzales, & L.G. Campbell. (1987). Ongoing post divorce conflict and child disturbance. Journal of Abnormal Child Psychology, 15(4), 493-509.

7. Johnston, J.R., M. Kline, & J.M. Tschann. (1989). Ongoing divorce conflict: : Effects on children of joint custody and frequent access. American Journal of Orthopsychiatry, 59 (4), 576-592.

8. Kalter, N., Ph.D. (1989). Long-term effects of divorce on children: A developmental vulnerability model. American Journal of Orthopsychiatry, 57 (4), 587-600.

9. Oppenheimer, K., Ph.D., R.J. Primz, Ph.D., & B.S. Bella. (1990). Determinant of adjustment for children of divorcing parents. Family Medicine, 22(2), 107-111.

10. Pearson, J. & N. Thoennes. (1990). Custody after divorce: Demographic and attitudinal patterns. American Journal of Orthopsychiatry, 60 (2), 233-249.

11. Wallerstein, J.S., Ph.D. (1984). Children of divorce: Preliminary report of a ten year follow-up of young children. American Journal of Orthopsychiatry, 54(3), 444-458.

12. Wallerstein, J.S., Ph.D. (1985). Children of divorce: Emerging trends. Psychiatric Clinics of North America, 8 (4), 837-873.

13. Zaslow. M.J., Ph.D. (1988). Sex differences in children’s response to parental divorce: Research methodology and post-divorce family forums. American Journal of Orthopsychiatry, 58 (3), 355-378.


John Dunne, MD, is a psychiatrist in private practice in the Seattle area specializing in the evaluation and treatment of parents and children. Marsha Hedrick is a clinical psychologist in private practice in Seattle specializing in forensic evaluations of adults and children.

The authors wish to thank Janis P. Mayberry, PhD, for her assistance in analyzing cases contributed by her for this study. The editor wishes to acknowledge Dr. Richard Gardner’s review of this manuscript.

Address correspondence to: 216 1st Avenue South #333, Seattle, WA 98104.

Journal of Divorce & Remarriage, Vol. 2(3/4) 1994 by the Haworth Press Inc. All rights reserved.

Categories: Journals


AMERICAN JOURNAL OF FAMILY LAW, Vol 7, 175-179 (1993) 

, Venice, Florida

There are few activities in which a mental health professional can engage that are more emotionally arousing, controversial, and potentially damaging than performing a custody evaluation. The process is hampered by two key facts. First, the scientific literature on custody determination is woefully inadequate. Second, for every competent professional evaluator, there may be many more incompetent ones. 

For these reasons, it is important that attorneys be attuned to some of the strengths and weaknesses inherent in mental health experts’ custody recommendations. This article will outline a variety of issues that one might consider when questioning such an expert’s report on custody determination. 


Perhaps the greatest impediment to the mental health expert’s ability to provide fair, competent, and appropriate custody recommendations is the absence of a sound scientific body of research in this area. Currently, there is no clear-cut body of scientific data about some of the basic questions that underlie a custody recommendation. For example, there is an absence of strong scientific evidence regarding precise parenting characteristics that guarantee “good parenting.” Similarly, we lack sound research data regarding the effects on the future of a child who’s been placed with the “wrong” parent. Given the absence of well-established scientific data on these issues, this leaves the mental health professional with tremendous leeway in regard to how he or she decides to go about doing a custody evaluation and in the interpretation of the data collected for that investigation. As such, what one mental health expert might see as critical, another similarly trained professional might see as trivial. This leaves the court in a terrible quandary–one of which the court, at times, may not even be aware. 

The problem is well illustrated when a mental health expert who has an excellent courtroom presentation style is actually incompetent. The court, relying on someone believed to be an expert, actually receives poor advice that the court does not have the expertise to evaluate. Unfortunately, as noted above, many individuals engaged in the business of providing custody recommendations probably have no business doing so. Hopefully, the reader will find the information contained in this article useful in evaluating such a mental health professional’s report. 


The psychiatrist (M.D.), psychologist (Ph.D.), and social worker (M.S.W.) are the experts in our society regarding issues of mental health. Unfortunately, this author is not aware of any scientific evidence proving that an M.D. or Ph.D. or M.S.W. is any more competent in making a good custody decision than a well-seasoned family court judge. However, since these experts are often called upon to make custody recommendations, I will present my biases regarding some of the “ideal” characteristics to be found in the professional custody evaluator.

The examiner should be able to document having accomplished a significant number of custody decisions that reflect an unbiased record (e.g., the evaluator does not always recommend that the mother get the children).


Of the three professions noted in the above paragraph, the PhD. in clinical psychology is typically the one distinguished by the most training in basic science. Having a critical attitude about data of any kind, and the tools by which to understand the scientific literature pertinent to the case, the Ph.D. is probably the preferred professional. However, this is not always the case. It is especially not the case when the person doing the evaluation has no specific training in the area of child development. Key to making a custody recommendation is the ability to predict the future development of the child if placed with a particular parent. As such, the professional with only one graduate level course in child development would appear to have an insufficient background. Instead, the ideal mental health professional for doing a custody evaluation has significant training in the area of child development, with particular understanding of the stages of development and how they interact with the positive and negative attributes of each parent. 

In addition to the qualifications above, the ideal evaluator has significant training in psychopathology, with particular understanding of the factors that promote the development of mental disorders. In particular, the evaluator should have special expertise in the areas of personality and personality disorders. The clinician who lacks top-notch diagnostic skill is potentially short-changing the family and the child. 

The ideal evaluator has many years of experience as a practicing clinician. However, in addition, the examiner should be able to document having accomplished a significant number of custody decisions that reflect an unbiased record (e.g., the evaluator does not always recommend that the mother get the children). 

Finally, the mental health expert in this area must make it clear to the court that his or her tests, interpretations, and recommendations are potentially subject to error. The expert should not only make the court aware of this, but should give some indication to the court regarding the range and degree of possible errors involved. 


We are all subject to biases, some of which we are not even aware. Even the most impartial examiner can find himself or herself at times favoring a particular parent in a custody dispute for reasons that have little to do with the quality of the parenting offered. Given that this is potentially the case with even the most “objective” of examiners, the implications for the “hired gun” are obvious: the hired gun should not be allowed to give a custody recommendation. 

A second key issue in regard to the relationship between the expert and the parties involved is what is known as the problem of “dual relationships.” This exists when the expert has a relationship with one or more of the parents independent of the custody evaluation. For example, assume the wife has been seeing a particular therapist for individual psychotherapy and then offers his services to the court to provide a custody evaluation. In this instance, the examiner has a clear history of being supportive and helpful to, and most important, being on the side of the wife. This unquestionably biases the therapist, whether or not he or she wants to admit it. Such an individual should not be permitted to also then evaluate the entire family for a custody determination. 

Another example of the problem of dual relationships occurs when one of the parties enters into court-ordered therapy with a particular therapist and then afterward that therapist recommends that a full family evaluation be done. While the recommendation itself might be appropriate, it is inappropriate for the court-ordered therapist of one party to then perform the family evaluation. 

Trying to be therapist and evaluator at the same time increases the risk of biased “professional” opinions. 


Psychologists are divided themselves about the importance and appropriateness of psychological testing in making a custody determination. The fact that there are thousands of tests available in the psychological literature only compounds the problem. 

The use of IQ tests is one clear-cut area of controversy. Some consider IQ tests to be required in every case, whereas others consider IQ tests as highly wasteful and inappropriate for a custody evaluation. To this author, it would seem that if the intelligence of the children is an issue in regard to which parent might be better able to foster that child’s attributes, then perhaps IQ tests are relevant. Some evaluators may be viewed as adding them merely as a way to “pad the bill.” The IQ test is one of the most well-known and well-established assessment instruments associated with the work of the clinical psychologist. Accordingly, the reader should not be surprised that tests of less stature may be even more controversial. 

In recent years, several psychologists have attempted to develop “objective” measures that are specific to custody evaluations. For example, Bricklin has developed the Bricklin Perceptual Scales, and he claims a 90 percent agreement rate between his scales and judges’ determinations. Similarly, the Ackerman-Schoendorf Scales for Parent Evaluation of Custody (ASPECT) have recently been introduced and the authors claim a 90 percent agreement with judges’ custodial decisions as well. The mental health expert who does not use these tests should be queried as to why not. Those examiners who use these scales should be questioned regarding the amount and quality of research on these scales, what specific validity evidence exists in the research literature about them, and what are the known sources of error in these scales, as they relate to the case at hand. 


While the choice of psychological test is controversial enough, interpreting test data can be even more controversial. In my own practice, both clinically and in training doctoral-level psychologists, I have often seen two professionals look at the same data and come up with quite different interpretations. Some psychologists may present computer interpretations to imply a more “objective” presentation, but there are problems here as well. First of all, the computer interpretation is limited by what the human being puts into the computer interpretation program. While the computer will be consistent in applying the rules it has been given, it does not mean that the rules it has been given are necessarily correct. Further, there are so many interpretive computer programs available to psychologists these days, the amount of scientific validity evidence for them varies tremendously. As such, the psychological examiner should be examined on this particular issue.

If the psychologist has a particular choice in mind as to who should receive custody, he or she may examine the psychological test data searching for evidence to confirm if as opposed to looking at evidence that might disconfirm it.


Additionally, the two most well-known and widely used major personality inventories, the Minnesota Multiphasic Personality Inventory (MMPI) and the Millon Multiaxial Clinical Inventory (MCMI), when given to the same person, may yield two very different computer interpretations. The bias of the examiner may come further into play when he or she examines the two discrepant personality inventories on the same individual. Clearly, the tendency to selectively pick out results becomes a problem. 

Laypersons and psychologists alike are prone to search data looking for instances that confirm one’s ideas. In other words, if the psychologist has a particular choice in mind as to who should receive custody, he or she may examine the psychological test data searching for evidence to confirm it as opposed to looking at evidence that might disconfirm it. He or she may then selectively pull out those pieces of test data to present to the court but inadvertently (or perhaps not inadvertently) leave out those data points that might contradict the psychologist’s recommendations. 


Many custody evaluators do not specifically and systematically observe the interaction between each parent and each child involved in the custody evaluation. The psychologist who fails to make systematic observations of how each child and each patent interact on various tasks may be doing the family a disservice. In this case, the examiner restricts information to that which is secondary to the basis of the custody question: namely, the child-parent interactions that are most likely to produce the best benefits for the child.

The bottom line is that the psychologist who does not provide a thoroughly convincing and compelling argument for the interpretation of his or her interview, test data, and observations to provide a custody determination is not doing the family or the court a useful service.


An excellent way to assess parent-child interactions is to videotape each parent with each child independently engaged in a variety of tasks. This permits the psychologist to review those interactions when alone, and also to invite other colleagues to view them and give opinions. This expands the psychologist’s ability to assess the case beyond interviews, psychological tests, and records. The psychologist who does not do this should be prepared to defend why it hasn’t been done. 

A key point in picking tasks for the parent-child interactions to be observed is that they should not be biased toward either parent. For example, if one parent knows how to sew and the other does not, it would be unfair to instruct each parent to teach the child how to sew on videotape. Tasks such as playing a game, solving a problem, or teaching the child something new are useful indicators. 


It is not uncommon to read a psychological report of 10 to 15 pages covering the interview, test data, and so on and then read the final section in which recommendations are made that have no clear, logical connection to all of the preceding information. The court should expect the recommendation section to provide a logical, clear, and convincing justification for why one parent should be named the primary residential parent and the other should not 

Psychological examiners, like other human beings, often make errors in logic. For example, assume all of the data collected on the father and the mother are relatively equal except that the mother has an elevation on her depression subscale on the MMPI. To award primary residential custody to the father purely because the mother has one test score suggesting an elevation in depression represents an inadequate justification by itself. In fact, even if one parent has some type of psychopathology, that does not therefore mean that that parent is a poor parent. The bottom line is that the psychologist who does not provide a thoroughly convincing and compelling argument for the interpretation of his or her interview, test data, and observations to provide a custody determination is not doing the family or the court a useful service. 

Another problem regarding the rationale for a custody recommendation is that some evaluators misrepresent the value of their recommendations. For example, one psychologist noted in his report to the judge that the method he adopted for conducting the custody evaluation was based on a method used by a former president of the American Psychological Association (APA). This implies that the psychologist’s report has merit. Unfortunately, this is a misrepresentation of the report’s value for at least three reasons. First, the man who became APA president made a major political achievement. However, there is no evidence that this APA president’s approach to custody determination won him the election. Second, even if there is merit to this APA president’s custody determination procedure, there is no evidence that the particular psychologist who used the method has the same competency as the APA president in administering and interpreting this method. Finally, and most importantly, there is no strong scientific evidence that this APA president’s procedure is the method of choice for performing a custody evaluation. It is the scientific literature that should guide custody evaluation procedures, not rhetoric nor the charisma of any one statesman. The rationale underlying a custody recommendation has the most value when scientific data is provided to support it. 


Custody battles are heart-rending. Children’s futures are at stake. Scientific evidence to guide custody decisions is nowhere near the necessary level for experts who need support in making such decisions. Until the scientific literature on custody determination matures, the report of the mental health “expert” should be viewed with a critical eye. 


Ira Daniel Turkat, PhD., is the chief psychologist at Venice Hospital and is on the clinical faculty of the University of Florida College of Medicine. He maintains a private practice in Venice, Florida. 

Categories: Journals


Speak Out for Children (a publication of the Children’s Rights Council) 17(2):6-10, 2002.

Richard A. Gardner. M.D.  

My primary reaction to the Kelly/Johnston article was that the authors do not appreciate that if the notions they promote in this article are taken seriously, they are contributing significantly to the weakening of women’s positions in courts of law.  By denying and/or discrediting the PAS, they are depriving mothers who are victims of their husband’s PAS indoctrinations (an increasingly frequent phenomenon) of the most powerful weapon they can possibly use in a court of law to defend themselves.  The husband’s lawyer, almost invariably, welcomes any opportunity to discredit the PAS and argue before the court:  “Your honor, everyone agrees that these children are alienated.  All you have to do is listen to the children, and it will be obvious that they are alienated from their mother because of her neglect and abuse. The mother is claiming that she is the victim of the father’s PAS indoctrinations.  Your honor, PAS is a discredited and defunct theory.  Here is an article by Kelly and Johnston that confirms this.” The mother and her lawyer recognize that if the court “buys in” to the father’s lawyer’s arguments,  the court will not then take seriously the mother’s claim that the father is a PAS indoctrinator, will “believe the children,” and possibly deprive her of primary custody. I will come back to this important and crucial point.
The authors state that I have written that the indoctrinating parent is usually the mother.  This was certainly the case during the 1980s and well into the 1990s.  However, in the last few years I have noted a gender shift, so that at this point I consider fathers and mothers to be equal with regard to the number of cases in which parents are alienators.
In the section entitled, “Criticisms of the PAS,” the authors suggest that I am not aware of the multiplicity of other factors that can bring about alienation between children and parents.  This statement has absolutely nothing to do with reality.  Prior to my first publication on the PAS in 1985, I wrote extensively about the various kinds of family problems that could result in children’s becoming alienated from a parent.  PAS is just one subtype of parental alienation, a subtype that involves an alienating parent’s programming a child into a campaign of denigration against the other parent, who is usually loving and dedicated.  
The authors lead the reader to believe that the PAS is not to be found in DSM-IV (1994) because “there is no commonly recognized or empirically versified pathogenesis, course, familial pattern, or treatment selection.”  First, PAS is not to be found in the 1994 edition of DSM-IV because, at the time it was being prepared (1990-1993), there were too few articles in the scientific literature to justify a submission. Their statement implies a submission and rejection; there was never even a submission. The DSM-V is scheduled for publication in 2010.  Committees are scheduled to start meeting in 2003.  At this point, I have lists of 135 articles (by over 150 authors) on the PAS in peer-review journals and 65 citations from courts of law in which the PAS has been recognized.  Furthermore, in November 2000, after a Frye Test hearing, a court of law in Florida concluded that PAS has received such widespread acceptance in the scientific community that it warrants recognition in courts of law (Kilgore v. Boyd).  This ruling was subsequently upheld by a Florida Court of Appeals (Boyd v. Kilgore). These lists are being continually updated on my website (  These lists of  peer-reviewed articles and legal citations will be included when a submission on the PAS is proposed to the DSM-V committee.

The authors state:

“ If PAS is considered a ‘grouping of signs and symptoms, based on their frequent co-occurrence,’ it should be considered a nondiagnostic syndrome, but this sheds no light on cause, prognosis, and treatment of these behaviors.”

PAS well satisfies the syndrome requirement that it is a “grouping of signs and symptoms, based on their frequent co-occurrence.”  This is what makes it diagnostic.  One makes a diagnosis on the basis of the frequently occurring cluster of symptoms.  The term “nondiagnostic syndrome” is mutually contradictory to the point of being almost meaningless. A syndrome is used to make a proper diagnosis. If the PAS cluster is not a syndrome, then it cannot be used to make a diagnosis.  Accordingly, there is no such thing as a nondiagnostic syndrome. It does not speak well of the authors to use an oxymoron in a scientific paper.

The authors claim that the PAS sheds no light on cause, prognosis, and treatment.  It is not necessary for the name of a disorder—whether it be a syndrome or any other label for the disorder—to shed light on the cause, prognosis, and treatment of the disorder. Down’s Syndrome is a syndrome, yet its genetic cause was not discovered until many years after its description.  We still have no treatment for it.  That does not preclude the fact that it is a syndrome.  A syndrome is not defined by elucidation of its cause, prognosis, and treatment, but on the basis of the cluster of symptoms that appear together.  The vast majority of disorders listed in DSM-IV are syndromes and were once labeled as such prior to their inclusion.  For example, Tourette’s Syndrome, when accepted into DSM-III, became Tourette’s Disorder.  Inclusion in DSM-IV does not require knowledge of cause, prognosis, and treatment. Obviously, these are important considerations, but are of concern after one has made the proper diagnosis.  My books and articles on the PAS deal in depth with causes, prognosis, and treatment (Gardner, 1992, 1998, 2001).

The authors continue:  “Hence, the term PAS does not add any information that would enlighten the court, the clinician, or their clients.…”  My experience has been just the opposite. The PAS diagnosis, being one cause of parental alienation, can be very useful to the court.  Of all the sources of parental alienation, it is one that directs attention to the programmer. It makes the court’s job easier when this particular subtype of parental alienation is identified.  I am sure the authors would agree that it is better to use the term “myocardial infarction,” rather than “heart disease” (which is the diagnosis doctors made prior to the late 19th century).  The history of medicine and science is the history of progressively greater refinements.  Breaking down a disease into its subtypes allows for a more specific “targeted” treatment.  By using PA for PAS the authors are causing confusion and reversing the trends of history.

The authors’ claim that the debate around PAS results from the fact that I am using a medical syndrome to explain family orientation and interaction issues.  This is not true.  In all my writings I discuss in detail the various family interactions involved in PAS.  The vast majority of disorders in DSM-IV involve family interactions, but descriptions of the family issues are not necessary for making the diagnosis. The primary  reason for the debate is that PAS is a product of the adversary legal system, and the families in which the PAS is present believe (very naively) that the courts provide  their best hope for resolving their disputes.  In the adversary system, it behooves the programming parent to deny the existence of the PAS, and it behooves the victim parent to try to convince the court that PAS is very much a real entity.  The primary source of the debate is that lawyers are continually looking for reasons to deny the existence of PAS and for mental health professionals who will support the denial of PAS programmers in courts of law.  If deniers and distracters of PAS were to say to inviting lawyers:  “You know, I’ve been giving a lot of thought to the PAS, and I think Gardner is right.  It does exist, and it’s important to say so in courts of law in order to help defend victim parents,” they would lose business.  

Another reason for the debate is that in the period when mothers were more likely than fathers to be PAS indoctrinators, those who recognized PAS risked being labeled as biased against women and “sexist.”  And the equation “PAS equals bias against women” has carried over now into the era when men are equally likely to be PAS indoctrinators. Unfortunately, the dictum is deeply embedded in the psyche of many in the legal and mental health professions.  In the past,  denial of PAS became a weapon for women who were PAS indoctrinators. Now that men are equally likely to be PAS indoctrinators, the deniers of PAS are hurting women victims of their husband’s PAS indoctrinations.  

The authors then state:  

“There is a relative absence of any empirical or research support for the reliable identification of PAS….”  

I do not consider over 135 articles by over 150 authors and 67 legal citations to indicate that “there is a relative absence of any empirical or research support for the reliable identification of PAS.”   

The authors then  claim that my articles on the PAS have been self-published.  This absurd statement has absolutely nothing to do with reality.  At the time I write this, my website lists 14 published articles, 4 in press, and one submitted for publication.  All 19 are in peer-review journals. Not one of my articles on the PAS has ever been self-published.

Next, the authors would lead the reader to believe that I do not concern myself with historic reasons for the children’s resistance to visit with the alienated parent.  My 1998 book (which the authors cite) describes in great detail the historic reasons:  the family factors, the environmental factors, and the individual psychodynamic factors.  Their statement that I have circumscribed PAS, totally oblivious to the family factors, has nothing to do with anything that I have ever written.  Their citations to Rand, Walsh and Bone on that point would suggest to the reader that these authors support Kelly and Johnston with regard to this criticism.  The Rand, Walsh and Bone articles do just the opposite.  They, as do I, recognize the complexity of family factors that are operative in bringing about PAS.  We see here yet another misrepresentation by the authors.

The authors are correct when they claim that in the severe cases of PAS, I recommend placement of the child with the hated parent and court sanctions.  The authors would lead the reader to believe that this is the case with the vast majority of PAS cases that I see. I have repeatedly stated in my writings that these are “last resort” recommendations and apply to only about 10 ten percent of all cases that I have seen.  These are the cases in which the indoctrinating parent (whether mother or father) is relentless in the indoctrinations and sometimes paranoid.  These are the cases in which it is quite clear that if the children are not transferred, there will be lifelong alienation.  My follow-up study of 99 PAS children provides compelling evidence for this conclusion (Gardner, 2001).

The authors claim that there is:

“… a lack of empirical support for PAS as a diagnostic entity.”

Apparently, the 135 articles, most of which are based on empirical experiences, do not provide enough support for the authors.  The authors then desribe:

“The barring of testimony about PAS in some courtrooms.”

True, some courts have barred PAS, which is not surprising for a newly-described disorder being adjudicated in a court of law.  But the authors make absolutely no mention of the 65 courts of law that have recognized PAS and that it has passed a Frye Test hearing.  The authors then claim that PAS involves:

“The overly simplistic focus on the brainwashing parent as the primary etiological agent.”


It is  true that I do focus on the brainwashing parent, but it is not true that this is “overly simplistic.”  The fact is that when there is PAS, the primary etiological factor is the brainwashing parent. And, when there is no brainwashing parent, there is no PAS. This does not mean that all alienated children have brainwashing parents. What this means is that there is a subcategory of alienated children who do have brainwashing parents.  When there is a primary cause, it is useful to label it as such.

With regard to the frequent misapplication of the PAS diagnosis, that is true.  There are abusing fathers who claim that the children’s alienation has nothing to do with their abuses, but is the product of the children’s being programmed into PAS by their mothers.  And there are mental health professionals who do not properly make the diagnosis, sometimes with disastrous results for the family.  These misapplications are unfortunate, but it is illogical to blame them on the disorder or the person who first introduced the term and described its etiology, pathogenesis, clinical manifestations, and treatment.  We do not blame Henry Ford for automobile accidents, nor should we get rid of cars because of them.  Nor do we blame the Wright brothers and get rid of airplanes because there are airplane accidents and terrorists will use them as human bombs.

The authors go on to “reformulate” the PAS.  They claim, somewhat condescendingly, that their focus is on the alienated child and that I erroneously focus on the alienating parent. However, without the alienating parent, the child wouldn’t be alienated.  Without stopping the alienation, the child is going to continue to be alienated.  By reducing the alienator’s access or changing custody (in severe cases), I am certainly focusing on the alienated child.  The implication here, also, is that I have not used the alienated child as my starting point.  I have.  And when I use the child as a starting point, I see a typical constellation of symptoms:  1)  The Campaign of Denigration, 2) Weak, Frivolous, or Absurd Rationalizations for the Deprecation, 3)  Lack of Ambivalence, 4)  The “Independent-Thinker” Phenomenon, 5)  Reflexive Support of the Alienating Parent in the Parental Conflict, 6)  Absence of Guilt Over Cruelty to and/or Exploitation of the Alienated Parent, 7)  Presence of Borrowed Scenarios, and 8)  Spread of the Animosity to the Extended Family and Friends of the Alienated Parent

Most of these symptoms are seen in the moderate cases, and all are usually seen in the severe cases.  When these symptoms are present, I look back into the family to ascertain the cause: it’s usually a programmer.  When one sees another constellation of symptoms of alienation–e.g., symptoms of physical abuse, emotional abuse, sexual abuse, and neglect–one usually sees other reasons having little, if anything, to do with PAS programming.  The authors consider themselves to be looking at the whole picture, implying that I do not.  If I didn’t look at the whole picture and focused on the child only (as the authors profess they are doing), I would not have identified the main cause: the programming parent.  Anyone reading any of the many books and articles I have written in the field of child psychiatry will easily see that my approach has always been on the whole family with a particular focus on protecting the child from pathological family influences.

The authors then describe what I call PAS and what they call “the alienated child.”  Basically, all they have done is given the  PAS another name and have dropped “the big S word.”  This muddies the waters. The history of science is the history of developing ever more discrete differentiations. The authors are going backwards. Their alleged contribution, their “reformulation,” is basically scientific regression.  What they are doing is just the opposite of  scientific progression.

As mentioned, the authors do not seem to appreciate that their discrediting and/or denying the PAS is a terrible disservice to women.  I have seen many women who are victims of their husbands’ PAS indoctrinations, women who know well that PAS exists, women who have sought my help in supporting them against their PAS-indoctrinating husbands in courts of law.  They know quite well that denying PAS’s existence weakens their cases. Such target mothers often find themselves helpless.  They cannot get help from therapists who are still mouthing the old mantras:  “PAS is just Gardner’s theory,” “PAS doesn’t exist because it’s not in DSM-IV,” and “PAS is not a syndrome.”  Lawyers, too, will tell them:  “PAS exists, but this judge will not recognize it.  I can’t use the word ‘syndrome’ in his (her) courtroom.” And these victimized mothers cannot even turn to the Women’s Rights groups, because they are still stridently taking the position that PAS does not exist, that PAS is not a syndrome, etc. etc.  

It is obvious, then, that women’s past denial and discrediting of PAS has now come back to haunt other women. Women are now being injured by their own weapons or, as the old saying goes, “They are being hoist by their own petards.”  Kelly and Johnston’s position, then, is contributing to the grief of women who are targets of their husbands’ PAS indoctrinations.


 Kilgore v. Boyd, 13th Circuit Court, Hillsborough County, FL., Case No. 94-7573, 733 So. 2d 546 (Fla. 2d DCA 2000) Jan 30, 2001.

 Boyd v. Kilgore, 773So. 2d 546 (Fla.3d DCA 2000).

Gardner, R.A. (1992) The Parental Alienation Syndrome:  A Guide for Mental Health and Legal Professionals. 

Cresskill, New Jersey: Creative Therapeutics, Inc..

Gardner, R.A. (1998) The Parental Alienation Syndrome, Second Edition.  Cresskill, New Jersey: Creative Therapeutics, Inc..

Gardner, R.A. (2001), Should Courts Order PAS Children to Visit/Reside with the Alienated Parent? A Follow-up Study.  American Journal of Forensic Psych


Categories: Journals
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