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S.P.A.R.C. | 
| Separated Parenting Access & Resource Center
"Keeping Families Connected"
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Parental Alienation And Enmeshment Issues
In Child Custody Cases
Daniel J. Rybicki, Psy.D., DAPBS
Excerpt from Dr. Rybicki's forthcoming book on Expert Witness Testimony and Forensic Psychology.
Relevant Clinical and Research Literature:
In recent years, custody evaluators and family therapists have encountered numerous
cases of highly dysfunctional behavior evident in divorcing couples. While scientific research
literature has not yet caught up with clinical descriptions, there have been several published
accounts of a process that some have come to label "parental alienation." Most notable and
most controversial in this history is the body of work by Dr. Richard Gardner (1987; 1992a;
1992b ). Others have popularized and expanded on Dr. Gardner's work (e.g., Darnell, 1998;
1999; Navarre, 1998), although the primary proponent of the PAS model has been Dr. Gardner.
It was Dr. Gardner who labeled this process a "syndrome", implying that a set of behavioral
factors or "symptoms" are present in varying combinations to form a fairly consistent profile or
pattern of concerns. The implication is that this syndrome may have common causes and
treatments, leading Dr. Gardner to apply his "medical model" terminology to explain his repeated
clinical observations. There has been considerable debate over whether or not this account meets
the requisite definition of "syndrome" (e.g., Bricklin & Elliott, 2000; Johnston and Kelly, 2001;
Poliacoff, 2000; Willams, 2001), there is sufficient professional discussion of this topic to
warrant closer scrutiny of just what it is that is being described in certain divorcing family
systems.
Parental alienation is described by Ward and Harvey (1993) as the creation of "a singular
relationship between a child and one parent, to the exclusion of the other parent. The fully
alienated child is a child who does not wish to have any contact whatsoever with one parent and
who expresses only negative feelings for that parent and only positive feelings for the other
parent. This child has lost the range of feelings for both parents that is normal for a child." The
definition suggests a range of levels of severity, and implies that several factors may contribute
to this observed outcome in a family system. The alienation process is believed to set up
conditions that interfere with the quality of the relationship with the alienated parent, which in
turn adds to maladjustment and distortion in the child. According to Ward and Harvey, the
alienating parent is motivated by residual issues from unresolved problems in the marriage or
divorce. At times, the motivations may be unconscious in the alienating parent. At times, the
issues are more overtly owned and expressed.
As this model implies, there is a heavy emphasis on examining the role of the parent who
might act in ways which lead to alienation in the child. This viewpoint is in keeping with the
position offered by Gardner whose definition of parental alienation syndrome sets forth a specific
diagnosable disorder that has eight core criteria which must be met to earn this label. Gardner's
formulation of the parental alienation syndrome (PAS) followed some of the formative writings
of Wallerstein and Kelly (1976, 1980) which reported on observations of a clinical phenomenon
in which the child's strident rejection of a parent was accompanied by strong resistance or refusal
to visit with the alienated parent. This pathological alignment between a parent and a child to the
exclusion of the other parent was identified several years prior to Gardner's earliest writings in
the area. It was Gardner however who developed a more elaborate and detailed description and
offered a series of criteria for assessing this alienation process in its most disturbing form when it
appeared as a pathological syndrome.
As noted here, the clinical descriptions in the literature tend to focus on the motivations
and behaviors of the alienating parent and to a lesser extent on the children involved in this
process. There has been a great deal of dispute and disfavor shown amongst judges, researchers,
and policy makers to this formulation, and this has led to more recent focus on a continuum of
family system dynamics wherein alienation and estrangement may take place. The more
acceptable view amongst a body of researchers and authors is that PAS and other forms of
alienation are part of a larger set of dysfunctional family system dynamics that may become
pronounced in times of marital conflict, separation, or divorce. There has been greater emphasis
on the concept of the alienated child (e.g., Kelly and Johnson, 2001) which has sought to
examine the methods by which a child may become estranged from a parent. The new
formulations have not totally rejected the possibility of PAS being a bona fide form of
disturbance, but they have described a host of other formulations and factors which must be
considered, along with pointing out the range of complexity that can be associated with parent-child relationship problems in a conflictual and divorced family system (see Lee and Olesen,
2001). These authors would find less to disagree with in their view with the earlier writings of
Waldron and Joanis (1996) or with Ward and Harvey (1993) who have viewed the alienation
process as a form of family system disturbance. They might agree that alienation may even be a
defense mechanism which may serve the purpose of maintaining the alienating parent's
symbiotic dependence on the child, assist in managing the anger and revenge felt by the child or
alienated parent, protecting the alienating parent's self-esteem, or avenging the alienated parent's
abandonment of the family. They find multiple pathways to observations of alienation in a family
system, and they find the model offered by Gardner to be too simplistic and too unfair primarily
to mothers. And, while these new formulations of the "alienated child" or alienation process in
divorcing families offer a much improved clinical working model, they share with Gardner the
fact that they are largely untested in terms of empirical research on diagnosis and intervention
strategies.
Several authors such as Kelly and Johnston (2001) or Dallam (1998a, 1998b, 2000) have
severely criticized Gardner for his unscientific model of PAS. There are those that have taken the
position that the PAS as formulated by Gardner does not meet scientific standards, and therefore
fails to meet Frye or Daubert/Kumho standards for admissibility. We will discuss these issues
further in a subsequent section of this paper. However it should be understood that while one
might argue the scientific and legal status of this label, the fact remains that this type of
phenomena has repeatedly been observed to varying degrees in a large number of custody cases
(witness rising frequency of topic in professional literature, in seminars at American Academy of
Forensic Psychology, e.g. Nicholas, 1997). Clearly the terminology and assessment methodology
needs work, and there is a serious need for more empirical data to be gathered in this area of
alienation and disturbed family systems dynamic in the conflictual family post-separation or
post-divorce. However, there are emerging positions that seem to flesh out more of the important
domains to evaluate, and therefore give the custody evaluator more useful guidance for
conducting fruitful and fair assessments.
Given that at least ten percent of divorcing couples face intense conflict over custody
issues, the potential is fairly large for the undercurrents of tension and conflict to produce
conditions in which clinicians will report alienation and enmeshment concerns within the family
unit. The intense bitterness which follows from such high conflict divorce may fuel the resulting
disturbed communications which in turn yields various forms of interference with visitation and
undermining of respect for the noncustodial parent. Studies of children growing up in such high
conflict divorce circumstances find that these tensions may continue relatively unabated over an
extended period of time (e.g. Sullivan, 1997). The negative effects of such conflict and tension
upon subsequent child development has been described elsewhere by authors such as Johnston
(1989; 1994; 1995) and clearly documents that children who are caught in such battle zones will
often develop a number of psychological problems and adjustment concerns. While debate
continues over whether or not the Parental Alienation Syndrome is a term that meets Frye and
Daubert standards (e.g., Bricklin & Elliott, 2000; Dallam, 1998; Garber, 1996; Poliacoff, 2000;
Williams, 2001; Wood, 1994), there are several recent reports by sources such as Clawar and
Rivlin (1991), Lund (1995), Turkat (1994), Stahl (1999) and Hysjulien, Wood, & Benjamin
(1994) that have helped to establish this phenomenon as a major concern in child custody
matters. These authors point out the importance of considering the impact of parental alienation
in seeking to resolve custody and visitation disputes, particularly since this process often plays a
prominent role in causing unnecessary disruption in visitation and in the promotion of the
relationship with the noncustodial parent. Legal and therapeutic interventions have been
suggested by Gardner (1992a; 1992b) which are endorsed by some of these authors as well. In
order to understand the controversy and the current state of affairs, it may be useful to begin with
a summary of what Gardner has said, and how people have reacted to his positions.
Gardner (1987) is credited as being the first to coin the term "parental alienation
syndrome", although Stahl (1999) suggests that the rudiments of this family process were
reported originally by Wallerstein and Kelly (1976; 1980) when they discussed the alignment
process in divorcing families. Others picked up the study of this issue by examining the nature of
high conflict divorce, with Johnston and her colleagues offering useful insight into this dynamic
(Johnston, 1989; 1993; Johnston & Campbell, 1988). Gardner sought to formalize the model into
a working diagnosis and labeled the process as parental alienation syndrome with eight specific
criteria. These include features deemed common in children with moderate to severe PAS.
According to Gardner, the evaluator will observe:
- A campaign of denigration
- Weak, absurd, or frivolous rationalizations for the deprecation
- Lack of ambivalence
- The "independent-thinker" phenomenon
- Reflexive support of the alienating parent in the parental conflict
- Absence of guilt over cruelty to and/or exploitation of the alienated parent
- The presence of borrowed scenarios
- Spread of animosity to the friends and/or extended family of the alienated parent.
As Gardner notes, children "who suffer from PAS will exhibit most (if not all) of these
symptoms. This is almost uniformly the case of the moderate and severe types...[although] in the
mild cases one might not see all eight symptoms."
Some additional support for the value of Gardner's conceptual model comes from work
by Dunne & Hedrick (1994), Rand (1997) and Nicholas (1997). Gardner's criteria were found
useful for differentiating cases of parental alienation from other types of postdivorce concerns.
As reported by Dunne & Hedrick (1994), the cases of parental alienation syndrome appeared to
be primarily a function of the pathology of the alienating parent and that parent's relationship
with the children. The research by Nicholas suggests that the alienating parent may not always
display pronounced pathology, but commonly share the feature of a tendency to distort reality. In
the more severe cases, the alienating parent demonstrates marked personality disturbance.
These writings are unfortunately largely nonempirical case studies, and reflect clinical accounts
of what may be seen by others as one extreme of the continuum of alienation concerns. Other
less severe cases and other causes of disturbed parent-child relationship dynamics in the post-divorce environment are outlined in some detail by Kelly and Johnston (2001). We will return to
these points after some additional summary of the classic and somewhat extreme position offered
by Dr. Gardner.
According to Gardner's model, the primary parent engaging in alienation behaviors is
likely to be the mother although there are times when the father is the perpetrator of the
alienation (Gardner, 1992a; 1992b ; Ward & Harvey, 1993). Gardner estimates that 9 out of 10
cases involves the mother as the alienating parent, and the father being the parent who is the
outcast, rejected by the children, and prevented from developing or continuing to enjoy an
effective parent-child relationship with these children of divorce. A campaign of denigration is
described by these authors where the father is cast into the role of the villain, with the mother
playing the victim role and the child instructed to fear and reject the father. Gardner describes the
"programming mother" as angry, critical, and distant. Elements of projection, overprotectiveness,
reaction formation, and fury are outlined as underlying factors. Programming of the child may be
very overt or very subtle. Name calling, innuendo, and nonverbal forms of hostility may emerge
in the course of the alienation process. Destruction of remnants of the father (including gifts
given to the child by the father) may be part of a pattern of programming. More subtle forms may
include baring the father from coming to the door.
"A common maneuver is to require the visiting father to park his car
in front of the house and blow the horn when he arrives. He is not
permitted to come to the doorstep, let alone, ring the bell. Although
not stated, the implication here is that this very act might somehow
contaminate the whole household (Gardner, 1987, p.86)."
The answering machine is commonly used to screen calls, and the father's messages may
be lost or erased. Father is clearly on the unacceptable list of callers. Rigid adherence to a
visitation schedule and threats of calling the police are also seen by Gardner as forms of
programming and manipulation. "Visitation obstructionism is a very powerful vengeance
maneuver...[as is]..withholding the children (Gardner, 1987, p.93.)." Gardner goes on to note
how the mother will imply that father is ill-equipped to care for the child by preventing him
access to the child when minor illness is present in the child. Sarcasm, criticism, and efforts to
align with the children against the father are also noted.
"There are a wide variety of other ways in which a mother may
contribute to the child's alienation against the father. She may not
forward to him copies of school reports...She may refuse to allow the
father to join with her in teacher's conferences...A common maneuver
is not giving the father copies of school photographs (Gardner, 1987,
p.95.)."
Gardner notes that these efforts at alienation have included taking the child to a therapist without
the consent of the other parent, and then expressly prohibiting the therapist from communicating
with the father.
"Unfortunately, many therapists go along with this and thereby
unwittingly contribute to the perpetuation of their patient's parental
alienation. Confidentiality is used here in the service of perpetuating
psychopathology (Gardner, 1987, p.98.)."
Varying degrees of alienation have been described, ranging from mild to moderate to severe. In
accordance with the level of severity of alienation, therapists such as Dr. Gardner have proposed consideration of varying levels of intervention by the court.
Those persons who challenge Gardner's model are most upset over these interventions, noting
that they are based on an untested and nonempirical or unscientific diagnosis, rely on an untested
model and theory, and carry extreme risks for harm to the child (e.g., Johnston, Walters, and
Friedlander, 2001; Kelly and Johnston, 2001; Sullivan and Kelly, 2001). We will also consider
these alternative approaches to intervention, but for clarity, let us proceed with our summary of
what interventions are suggested by Gardner.
In the most severe cases, the mothers are often seen as fanatic, using every mechanism at
their disposal to prevent visitation. They are obsessed with antagonism toward the father, and
may even demonstrate paranoid ideation according to Gardner. Stahl (1999) notes that there is
clear and consistent derogation of the alienated parent, with some cases involving a combination
of programming, brainwashing, and hostility that begins with the alienating parent and is taken
on by the alienating child. Issues of abandonment and betrayal help fuel this anger, coupled with
projection of blame and intense fear/anger. Fabrications of sexual abuse and other outrageous
problems are found in this group of parents. Children become fanatic and extreme as well,
demonstrating what he calls a folie-a-deux relationship. There is a sick bond with the mother and
children, such that the children suffer dramatically as a result. Ward & Harvey (1993) see the
child as highly enmeshed with the alienating parent against the villain seen in the father. The
child is seen as a victim, much like the mother, and the child is often required to keep secrets
from the father and to express his/her allegiance to the mother. Threats of withdrawal of love are
used to bolster this parental control over the child. Gardner suggests that psychotherapy for the
mother and child is essential in such severe cases. Gardner also calls for hospitalization of the
child or a change of custody, as steps taken to remove the child from further exposure to the
damaging effects of the parental alienation process.
"Accordingly, the first step in the therapeutic process is removal of the
children from the mother's home and placement in the home of the
father...The hope here is to give the children the opportunity to
reestablish their relationship with the alienated father, without
significant contamination of the process by the brainwashing mother.
Even telephone calls must be strictly prohibited for at least a few
weeks...Then, according to the therapist's judgment, slowing
increasing contacts with the mother may be initiated, starting with
monitored telephone calls...This period of slow and judicious renewal
of contact between the children and the brainwashing parent must be
monitored carefully so as to prevent a recurrence of the disorder.
(Gardner, 1987, p.226-227.)."
Some have questioned the value and wisdom of Gardner's suggestion for a
"parentectomy" in such severe cases of parental alienation (e.g., Isman, 1996; Lee and Olesen,
2001; Mauzerall et al., 1997; Poliacoff, 2000; Williams, 1990, 2001; Wood, 1994), arguing that
the "cure" is worse and more detrimental than the "disease." A more cautious approach would be
individually tailored for the specific needs of the case, but the recommendations might include
court orders which establish greater structure and place limits on the alienating parent, court
ordered therapy and case monitoring, and use of a special master or guardian ad litem to monitor
compliance and report further developments to the court (Stahl, 1999). The goal is help the
alienating parent understand the harmful effects of alienation, while working to address any
underlying pathology which may fuel the alienation process. Stahl notes that only in the most
critical of cases would there be support for a temporary disengagement with the alienating parent.
The moderate cases have mothers who appear as less fanatic but still quite enraged. Stahl
(1999) suggests that these parents are quite angry and often vengeful in their behavior toward the
other parent. They feel hurt, and expect the child to take sides and be loyal to them over their
relationship with the other parent. Stahl agrees with Gardner in noting that moderate alienating
parents will work very hard to prevent visitation and to interfere with the quality of the
relationship between the father and the child. They are unreceptive to complying with court
orders but will do so minimally to avoid negative legal consequences. They may still bring up
sexual abuse allegations, but they can differentiate between preposterous claims and those that
may have some validity. They seem to delight in hearing negative news about the other parent
and they communicate their dislike of visitation arrangements. They often refuse to speak to the
other parent and may make derogatory remarks about them to the child. They will hold fast to
their view of needing to protect the children from this other parent and see the other parent as
untrustworthy, yet appear more subtle in their expression of these views with the child, friends,
or therapist. The children from this system will mirror the level of severity, and like the mother,
appear less fanatic but still guarded and prone to acting out. Like other high-conflict families
(Johnston & Campbell, 1988; Johnston & Roseby, 1997), there will be a high level of anxiety,
splitting, insecurity, and distortion, with one parent set up as the good parent and the other as the
bad parent. Children will have difficulty in integrating positive and negative images of each
parent, but this will be less pronounced than is apparent in the severe alienation family system
(Stahl, 1999). These cases call for interventions that are less drastic than the severe cases. A
change of custody may still be considered, at least for a temporary measure (Ward & Harvey,
1993). Gardner suggests that therapy be conducted by one therapist working with both parents
and the children. The therapist should be court-appointed. The therapist will work to reduce the
overprotective and controlling efforts of the alienating mother, while empowering the children to
take care of themselves. The therapist will help the children appreciate the value and need for
visitation with the father, and will work to use increased visitation time to facilitate a more
effective interaction between them. This experience is monitored and helps the child to confront
the false assumptions they have held, and to learn new and more adaptive methods of relating to
the father.
Finally, the mild cases of parental alienation tend to be more focused and limited in
scope. Gardner suggests that these parents have a more healthy bond with the children and are
able to recognize that alienation from the father is not in the best interests of the child. They are
more willing to take a conciliatory approach to the father's requests. They may still have little
regard for the importance of visitation and tend to have difficulty tolerating the presence of the
other parent at events important to the child. Stahl (1999) suggests that these cases will involve
subtle attempts at turning the child against the other parent and drawing the child into the
alienating parent's viewpoint. This may involve conscious and unconscious actions. The main
motive may be for the parent to look better in the eyes of the child. In most cases, Stahl suggests,
the results of this family dynamic will be a slight increase in loyalty conflicts and anxiety but no
fundamental change in the child's own view of the alienated parent. Intervention for this group
tends to be focused on specific issues, seeking to balance out the communications and dynamics.
Family systems work is done to overcome the divorce impasse which may fuel the alienation.
According to authors such as Gardner (1987; 2001b) and Ward & Harvey (1993), the
problems associated with the process of parental alienation tend to take on a life of their own,
and unless dramatic interventions are adopted, the ongoing conflicts and undermining of parental
value can serious endanger the mental health of the child. The emotional bond of the parent and
the child is disrupted and in some cases destroyed, causing irretrievable damage to the child's
overall development. The child is cast into the role of a "loyalty bind", having to choose which
parent they love more. Cartwright (1993) notes that prolonged alienation of the child may trigger
other forms of mental illness and that slow judgments by the courts tend to exacerbate the
problems. In keeping with recommendations from Gardner, this evidence points to the
importance of prompt and effective interventions in such cases.
Stahl (1999) reports that the children who are most susceptible to alienation are the more
passive and dependent children, or the children who feel a strong need to psychologically care
for the alienating parent. The child and alienating parent share a sense of moral outrage and there
is a fusion of feelings between them. While noting that there is a plethora of research studies in
this area, Stahl suggests that the clinical descriptions which have found their way into the
professional and legal literature offer some useful guidelines for consideration in custody
decisions. Long-term effects of alienation left unchecked may lead to various pathological
symptoms, which include but are not limited to:
- splitting in their relationships
- difficulties in forming intimate relationships
- a lack of ability to tolerate anger or hostility in relationships
- psychosomatic symptoms and sleep or eating disorders
- psychological vulnerability and dependency
- conflicts with authority figures
- and, an unhealthy sense of entitlement for one's rage that leads to social alienation
in general.
With the classic Gardner model of PAS in mind, it may be useful to review some of the
criticisms that have been levied against Dr. Gardner and his position. These criticisms have
highlighted the fact that Gardner's model has focused almost exclusively on the alienating parent
as the etiological agent of the child's alienation, ignoring considerable clinical research which
shows a host of other factors (e.g. Johnston, 1993). Kelly and Johnston (2001) contend that
"alienating behavior by a parent is neither a sufficient nor a necessary condition for a child to
become alienated (p.249)," implying that the model is too simplistic and ignores important other
data. Second, these authors contend that the model proposed by Gardner is largely untestable and
unfalsifiable because it is tautological. Third, they note that the PAS cannot properly be
considered a diagnostic syndrome as defined by the American Psychiatric Association, nor does
it reach the level of nondiagnostic syndrome. It does not offer any new information to the court,
and it lacks empirical support. Finally, these authors contend that using medical terminology
such as syndrome to describe a complex process of family dynamics, situational influences, and
individual pathology and development is to do more to obfuscate the nature of alienating
processes that appear in high-conflict cases. These arguments are carried further into challenges
to the entire PAS model at the level of admissibility (e.g., Williams, 2001; Zirogiannis, 2001),
and form a basis for questioning the utility of Gardner's model for custody litigation.
Instead, Kelly and Johnston (2001) seek to redirect our thinking to considering these
complex issues by examining family systems factors, situational factors, and individual factors
while formulating diagnostic impressions of dysfunctional families using a continuum model.
The draw attention to the concept of the "alienated child" who is "one who expresses freely and
persistently, unreasonable negative feelings and beliefs (such as anger, hatred, rejection, and/or
fear) toward a parent that are significantly disproportionate to the child's actual experience with
that parent (p.251)." Thus, there is a greater emphasis on the observed problem in the child, and
less of a simple indictment of the alienating parent as the only etiological factor of note. These
authors call for the evaluator to differentiate alienated children from children who resist
visitation for other reasons such as normal, realistic, and/or developmentally expectable reasons.
Normal separation anxieties, resistance rooted in alignment with one parent in high-conflict
divorce, resistance due to parenting style, resistance due to fears over an emotionally fragile
parent, and resistance due to remarriage or other relationship concerns are but a few of these
other formulations which Kelly and Johnston point out.
Their continuum model posits five positions, and includes one position for more serious
alienation of the type that Gardner might describe. Children's relationships with their parents
after separation and divorce may fall along this continuum. The most favorable position is a
positive relationship with both parents. Next the child may have an affinity for one parent over
the other, while still desiring contact and continuity with both parents. Allied children tend to
ally with one parent, and demonstrate a consistent preference, and want only limited contact with
the other parent. This third stage may be the result of pre-divorce personality or interpersonal
dynamics, parenting style, or developmental issues in the child. Level four on the continuum
reflects the outcome of realistic problems, such as exposure of the children to domestic disputes
or violence wherein the children become estranged. Abuse, neglect, family violence, chemical
dependency in the parent, and other factors may create the estrangement, and there may be no
alienating behaviors in the other parent to support the child's desire to restrict their contact with
the parent. Unlike alienated children, estranged children do not harbor unreasonable anger or
fear; they have a basis for their views and concerns. Finally, there is the position of the alienated
child, who may strongly resist visitation or contact with the other parent, and who will express
their rejection of that parent with some strident and strong sentiments, and without guilt or
empathy for the other's parent's feelings. This is a pathological response that emerges in the
absence of realistic factors as noted in the case of the estranged child. It is only this level that
may resemble some of the Gardner PAS or PA descriptions. Even then, Kelly and Johnston note
several other factors other than an alienating parent that may account for the observed alienation
in the child. These include systemic factors (child triangulated in intense marital conflict;
separation experienced as humiliation; impact of high-conflict litigious divorce; contributions of
new partners, extended family, and professionals), behaviors of the rejecting parent that
contribute to alienation (passivity and withdrawal; counter-rejection of the child; harsh and rigid
parenting style; critical and demanding traits; immature and self-centered behavior; diminished
empathy for the aligned child), and developmental stage vulnerabilities within the child (child's
age and cognitive complexity; child feels abandoned and rejected; temperament and personality
factors). Their full model is beyond the scope of this paper to address, but the central tenet is that
alienation as observed in the most severe cases may be the outgrowth of several factors all of
which require thorough and detailed consideration by any evaluator seeking to study a family
system for the court.
In keeping with the view that alienation issues are more complex than originally
formulated by Gardner, and in accordance with the concept that alienation reflects more of a
disturbance in family systems functioning than a distinct diagnosable condition, therapists
Margaret Lee and Nancy Olesen offer useful recommendations for improved assessment of
alienation in child custody cases. They contend that the simple three level intervention strategy
used by Gardner is also grossly oversimplified, and that problems with confirmatory bias might
foreclose the process of investigation when an evaluator finds some of the red flags listed by
Gardner. "Another problematic conclusion is that if one finds a parent engaging in alienating
behavior, the child is automatically seen as alienated. This might lead an evaluator to dismiss
other relevant concerns and issues. It also leads the evaluator to conclude prematurely that the
child is rejecting a parent because of these processes, even when that might not be the case
(p.283)." They urge the evaluator to take a more comprehensive and thorough investigative
approach, considering a host of factors such as those outlined by Kelly and Johnston (2001). The
offer a decision tree for conducting that assessment which begins with having the evaluator
consider whether or not the child's behavior resembles that of an alienated child (defined as "one
who expresses freely and persistently, unreasonable negative feelings and beliefs toward a parent
that are significantly disproportionate to the child's actual experience with that parent" citing
Kelly and Johnston, 2001, p.251). If there are such indicators, then the evaluation examines
parental behaviors, historical information, parent-child relationship history, and factors that
might lead to estrangement. They concur with Kelly and Johnston (2001) in seeking to
differentiate between alienation and realistic estrangement by considering whether the child has
been traumatized by various forms of abuse or neglect, or by witnessing domestic violence.
Other disturbances in parental adjustment (e.g., mental health problems, chemical dependency,
harsh parenting) may also be realistic factors that contribute to the estrangement. Beyond these
elements, Lee and Olesen call for consideration of the full family context, including bonding and
attachment issues, alignment with one parent or siblings, communications and identification
issues, etc. They go on to offer an outline of some of the sources of data which might help the
evaluator address these questions (e.g., clinical data from the parents and the child, direct
observations of all of the parties, collateral input and records, and psychological testing).
This model and the model offered by Kelly and Johnston (2001) both rest on extensive
clinical experience and case studies, just as does the PAS model proposed by Gardner. What is
different is that these new reformulations move from a simplistic medical model approach which
labels a diagnosable syndrome on the basis of a set of observed symptoms to a more rich and
clinically useful family systems and ecological approach that places issues of alienation within
the context of larger interpersonal dynamics, life experiences, and developmental processes. Both
approaches will require more empirical and scientific study, but one feature that favors these
reformulation models is their reliance on a body of empirical data from family systems research,
and their statement of multiple clinical pathways by which alienation and related problems may
arise. These components are more likely to meet Frye and Daubert standards for admissibility,
and many of these parts rest on a body of research that is already in the literature (e.g., Johnston,
1993; Johnston and Campbell, 1988).
Thus features outlined in the more sophisticated model of alienation offered by Kelly and
Johnston (2001) raise additional family systems concerns, and point to types of intervention
which have a sound theoretical footing within the field. They direct the clinician to consider
several commonly understood family dynamics which have been observed in a number of
clinical setting. For instance, they support the recommendation of studying the family process of
enmeshment. Just as alienation and estrangement may be concerns which help shape the
custody evaluation, it may be critical for the evaluator to carefully assess the level and degree of
any enmeshment or boundary disturbance that are present in a post-divorce family system. While
the literature does not often incorporate discussion of this topic into descriptions of parental
alienation, it would appear that enmeshment and overidentification of the child or children with
one parent may significantly contribute to the level and intensity of observed alienation
processes.
The term enmeshment has been widely used in the family therapy literature since it was
popularized by the work of Salvador Minuchin (1978). Describing psychosomatic families,
Minuchin and his colleagues outlined the impact of four disruptive family dynamics:
enmeshment, overprotectiveness, rigidity, and lack of conflict resolution methods. The offspring
in these families included anorexic girls who were so caught up in the family pathology that they
were unable to differentiate themselves and were locked into an illness that reflected the family
disorder. They were trapped in rigid roles with their other family members and they were treated
in such an overprotective manner so as to make a virtual moat around the family system which
blocked out the outside world. Attempts to penetrate these protective walls were rebuffed,
leaving no opportunity for corrective feedback, new learnings, or breaking the suffocating mold
that held the members captive.
"Enmeshment refers to an extreme form of proximity and intensity in
family interactions...In a highly enmeshed, overinvolved family, changes
within one family member or in the relationship between two family
members reverberate throughout the system...On an individual level,
interpersonal differentiation in an enmeshed system is poor...in
enmeshed families the individual gets lost in the system. The boundaries
that define individual autonomy are so weak that functioning in
individually differentiated ways is radically handicapped (Minuchin, et
al, 1978, p.30)."
Minuchin described the lack of clear ego boundaries between family members which
produced a form of fusion, a condition that interfered with a clear sense of self as apart from
the family while still being a part of the family. Taken with the family failure to have suitable
means for conflict resolution, Minuchin traced how the family system contributed to the
production of psychopathology in the members and how it was unable to move forward to more
healthy and adaptive roles. From this seminal work, a large body of literature has emerged which
has been most influential in the family therapy world. As with parental alienation described
above, varying levels and degrees of enmeshment may occur, ranging from mild and isolated
elements of enmeshment to more pathological and pervasive features. In divorcing families, the
impact of enmeshment can become more pronounced as the normal balancing influence of the
other parent is gradually diminished. Much like parental alienation, the phenomenon of
enmeshment may be found in varying degrees of intensity, with corresponding degrees of
negative impact on child development.
A number of recent publications have advanced the concept of enmeshment and
improved our methods of assessment and treatment for problems of family enmeshment (e.g.,
Blair, 1996; Ellis, 1994; Perosa & Perosa, 1993; Rogers, 1983; and Verheij, 1982). One may
conceptualize this problem as a form of being too close, where identity fusion between parent
and child is merged and it is difficult to tell where one begins and the other leaves off. In this
unhealthy dynamic, the child is unable to establish a clear identity apart from the parent, such
that actions of the child so significantly impact the apparent well-being of the parent that the
child is held captive to a role reversal and caretaker role, subsuming their own identity and needs
to those of the parent. Problems of this sort contribute to a myriad of developmental disturbances
in the children of such families (Anderson & Coyne, 1991; Bebbington & Delemos, 1996;
Cummings, 1994; Fullinwider & Jacobvitz, 1993; Koontz, 1983; Perosa & Perosa, 1993;
Schupak-Neuberg & Nemeroff, 1993; Shean & Lease, 1991; Waring and Patton, 1984). This
may include a number of forms of psychopathology (e.g., eating disorders, drug abuse) and
psychosomatic or psychophysiological disorders (e.g., chronic pain, headaches, gastrointestinal
disorders). Research has demonstrated that the model originally developed by Minuchin holds
true in terms of an established relationship between enmeshment and these various problems.
The phenomenon can be studied through observation of interactions and even more recently
through self-report measures of family functioning.
When this disturbance appears, the family dysfunction resonates throughout the family
system. It may even take on more pervasive elements by its multigenerational impact from
grandparents, through parents, and on to the youngest children. Therapeutic intervention is a
necessary first step, but this may fail due to premature termination when the treatment process
gets too close to the pathology. Ellis (1994) describes examples of this resistance to treatment
with case examples where the mother-child enmeshment led to the early withdrawal from
treatment. As noted above, the long-term consequences of enmeshment left unchecked can be the
development of serious emotional, developmental, and physical problems.
In one notable study, adolescents from such dysfunctional homes demonstrated
limitations in their coping abilities and in their development of a personal identity (Perosa &
Perosa, 1993). Dating relationships may be restricted and limitations in career exploration or
development may also follow from the negative impact of mother-child enmeshment
(Fullinwider & Jacobvitz, 1993). When enmeshment has been present with one spouse from their
family of origin, there tends to be restricted marital intimacies in the couple which appears to
reflect the perpetuation of family dysfunction (Waring & Patton, 1984). Clearly, the pathology
has the potential to transmit damaging messages and unhealthy family relations from one
generation to the next and beyond.
Unhealthy fusion may be increased through the process of divorce (Isaacs, 1987) where
any proclivity toward enmeshment is increased. However, the simple process of divorce does not
in itself account for the ongoing impact of enmeshment (Zastowny & Lewis, 1989), such that the
deleterious effects of enmeshment exist independently and have a life of their own if they remain
unchecked. The collusion, fusion, symbiosis, overconcern, and separation-individuation
problems of enmeshment create a constant state of vigilance which maintains the boundaries
between the internal and external world in a rather stable state of defense (Verheij, 1982).
Families where multigenerational enmeshment exist face added pressures at points of crisis and
tend to demonstrate even greater cohesion and growth-inhibiting controls over their members.
Therapeutic intervention is considered essential in such families according to these authors.
Implications for Custody Evaluators:
The early descriptions of alienation and high-conflict family disturbance offered by
Wallerstein and Kelly (1976; 1980) and the work on enmeshment (Minuchin et al., 1978) set the
stage for closer consideration of the types of variables that can yield impaired adjustment in the
parents and children of divorce. Additional controversy sparked by Gardner's formulation of the
PAS combined with intense debates in the mental health and legal literature have helped to move
the field further along the process of developing more complex and rich theoretical models.
While more research is clearly needed, there is an emerging literature that is very clear that
enmeshment and alienation dynamics can produce extremely serious developmental
consequences for persons caught in such dysfunctional family dynamics. The typical custody
evaluator is often faced with the task of observing these clinical features in the divorced family
system. While Gardner offers a list of eight criteria for PAS, and while he has formerly suggested
that evaluators use his Sexual Abuse Legitimacy Scale to distinguish false allegations of sexual
abuse from bona fide allegations, it has been noted that neither approach represents a true
psychological measure. In fact, Gardner has discontinued using the SAL in the face of such
criticism. The new alienated child model offered by Kelly, Johnston, Lee, and Olesen sets forth
several areas to evaluate, but lacks any specific formalized tools for measuring these issues.
Clinical judgment remains the primary methodology for even this more sophisticated analysis.
Thus, psychological assessment of parental alienation or enmeshment is complicated by
the fact that there are no specific or scientifically validated methods or scales for making this
type of family evaluation. More general reliance on customary clinical tools such as interviews,
family observations, collateral interviews, and psychological testing will only give the evaluator
a piece of the puzzle at best. These may have some established empirical support, but there
remains no set of cut-off scores or other methods for clear demarcation of estrangement versus
enmeshment, to highlight one example. It may be possible to use the recent formulations by
Kelly and Johnston to organize the data collected from these and other sources. Some may elect
to rely on Gardner's approach. And, to the extent that some empirical descriptors are available for
evaluating parents who engage in such alienating behavior or abuse, it may be possible to
combine these findings by using the summary of common profiles that appear in the literature
and compare them with the data from the subject in question. In this approach, the evaluator may
offer a statement to the court as to the degree to which a given parent or a given family resembles
the typologies listed by other authorities in the field.
Plausible rival hypotheses must be given serious consideration when the evaluator detects
evidence of what might appear to be parental alienation, enmeshment, estrangement, and other
such features in a given case. These complex models offer some parameters for making this type
of comparison. In the case of alienation, Poliacoff (2000) suggests that the child's ambivalence
towards a parent or their overt rejection of one parent may reflect several other factors such as:
- developmentally normal separation problems,
- deficits in the non-custodial parent's skills,
- oppositional behavior in the child,
- high-conflict divorce proceedings,
- other serious emotional or medical problems of one family member,
- child abuse and neglect,
- inappropriate, unpredictable, or violent behavior by one parent,
- incidental causes, such as the child's dislike of a parent's new roommate or lover,
- alienation by third parties,
- the child's unassisted manipulation of one or both parents, or
- fears for the absent parent's welfare.
Thus, Poliacoff joins with Kelly and Johnston (2001) and Lee and Olesen (2001) in suggesting
that the evaluator give consideration to these and other family features when the evaluator wishes
to document possible parental alienation or related family dysfunction. When the data do not
converge, or when key elements are missing from the profile, even Gardner (1998) will agree
that parental alienation syndrome is not the best label to describe the observed family problems.
Some specific suggestions for weighing the various findings in suspected alienation cases
is provided by Bricklin and Elliott (2000). They suggest that the evaluator may become alert to
parental alienation or other forms of distortion by attending to any and all "red flags" that arise in
the course of the custody investigation. In their handbook, these authors refer to a concept called
NBOAI -- which stands for not-based-on-actual-interactions. These NBOAI signs will help
the evaluator "to recognize situations in which a child is claiming to be true at a conscious level
material which is likely not based on his or her actual interactions with the persons represented in
the conscious position, but are more likely due to bribery, manipulation, intimidation, or a desire
to save a parent seen as impaired." Examples of this would include responses which sound
rehearsed; unasked-for-information too readily volunteered; responses given too quickly with
hardly any pause between question and response; Bricklin BPS scores which are skewed to one
championed parent; limited eye contact with the evaluator; and affect inconsistent with stated
events. Defiant, cursing, silly behavior taken to extremes may be a signal of prompting and
coaching, and less an indicator of one parent's lack of control. All of these examples should lead
the evaluator to consider parental alienation or other forms of distorted information emanating
from the assessment with the child or children.
The task of assessment is made somewhat easier when extensive information is collected
from a variety of sources. The common child custody evaluation practices of using psychological
testing, individual clinical interviews with each of the parents and each of the children, as well as
individual observations of the parents with the children will provide merely a starting point for
this evaluation. Bricklin and Elliott (2000) concur that there is a need for additional observations
of the child or children in interactions with both parents present. Where possible, this type of
observation may afford the evaluator a chance to witness how the child greets and interacts with
both parents collectively, then compare this with how the child relates to the parent in a one-on-one observation period. Information observations and more structured observations (e.g.,
Rybicki, 1991) may assist the evaluator in collecting this respective behavioral data. This may be
accomplished in part by having extended clinical sessions wherein one parent completes
psychological testing while the other parent interacts with the children, followed by points of
overlapping observations where the children spend time with each parent individually, and with
both parents in some collective situation. Additional collateral information must be collected
from a variety of sources, including careful review of various documents and records, as well as
directly contacting various collateral sources such as friends, family, neighbors, teachers,
therapists, and others who have additional information about the parents, children, and family
history. Where possible, reviewing family home movies or video, as well as photographs and
other records of family relations will assist the evaluator in gaining some insight into family
dynamics. And, clearly, a home visit becomes almost mandatory in order to further observe
family relations in the respective households. Developing an evaluation data collection system
that is consistent with prevailing professional standards (e.g., American Psychological
Association, 1994; Ackerman & Ackerman, 1997; Clark, 1997; Skafte, 1985; Stahl, 1994) is
imperative in order to amass the requisite data for determining the level and degree of alienation
and/or enmeshment factors which may be present in a given family system. Adhering to these
standards closely, and clearly specifying in advance the nature and types of evaluation processes
will also serve reduce liability concerns in this uniquely litigious area.
Legal Status of Parental Alienation Syndrome Testimony:
Recent years have witnessed considerable argument and debate over the legal status of
the PAS (e.g., Kopetski, 1998a, 1998b; Palmer, 1988; Warshak, 2001). Gardner and his
colleagues have been eager to attest to the fact that over 100 articles on PAS have appeared in
peer-reviewed journals. The majority of these articles have been non-empirical case-study and
clinical accounts, and most have been authored by Dr. Gardner himself. More recently there have
been some additional empirical studies on PAS related concerns, and on this basis, there has been
some emerging acceptance within at least a few jurisdictions of testimony on the basis of PAS
(Kilgore v. Boyd, 13th Circuit Court, Hillsborough County, Fl., Case No. 94-7573, Nov. 22,
2000). At the same time, there has been serious challenge to the PAS concept, with authors such
as Stephanie Dallam (1998b; 2000), Judge Williams (2001) and Lewis Zirogiannis (2001)
criticizing PAS as unscientific and not suitable for admissibility.
Expert testimony regarding concepts such as parental alienation syndrome is subject to
judicial review according to standards set forth in the Federal Rules of Evidence, and in several
legal precedent setting cases (Frye v. United States, 293 F. 1013, D.C. Cir. 1923; Daubert v.
Merrell Dow Pharmaceuticals, Inc., 113 S. Ct. 2786, 1993; Kumho Tire Co. v. Carmichael, 119
S. Ct. 1167 1999). Using these standards, authors such as Poliacoff (2000) join with Dallam,
Williams, and Zirogiannis to contend that Gardner and others have failed to demonstrate that
PAS meets these criteria for admissibility. They collectively argue that the theoretical concepts
of parental alienation syndrome lack empirical validation, rely too heavily on reverse logic to
demonstrate causality, and fail to meet expectations for peer review. At the opposite end of the
spectrum, authors such as Bricklin and Elliott (2000) join with Gardner (2001a) to cite over one
hundred articles on the PAS which have appeared in peer-reviewed journals. However, as noted
above, many of these remain largely nonempirical clinical writings based on case studies. To
date, there has been no suitable scientific validation of the PAS model as outlined by Gardner.
Other elements of the reformulation models offered by Kelly and Johnston (2001) at least rest on
some empirical data that would meet such criteria.
Poliacoff (2000) and Zirogiannis (2001) argue further that reliability and validity have not
been established with regard to use of the PAS term for parental alienation syndrome, nor have
the various levels of PAS been clearly delineated. Poliacoff cites somewhat dated cases in
Florida (e.g., In the Interest of T.M.W., 553 So. 2nd 260, FL. Dist. Ct. App., 1988) that have
adopted this position and refused to allow testimony around PAS claiming that it lacks general
professional acceptance. Yet, by using more specific criteria such as the eight factors listed above
by Gardner, there has been at least one successful Frye hearing on PAS which has allowed such
testimony as admissible on the basis of general acceptance (Kilgore v. Boyd, 2000). Other
caselaw in Wisconsin (Weiderholt v. Fischer, 485 N.W. 2nd 442, Wis.Ct. App. 1992) joins with
this perspective in ruling that there is at least "limited research data" to support the parental
alienation syndrome concept and its recommended forms of intervention. Bricklin and Elliott
(2000) note that there are now about forty legal rulings in which PAS has been recognized in
court (for update see www.rgardner.com/refs/pas), adding further weight to their contention that
the PAS is a useful clinical description for assisting the court in making custody
recommendations.
While many states have adopted the Daubert standards of admissibility, some states continue to
rely upon the Frye standards. The former set of standards as articulated in the Kumho decision
underscore the important gatekeeper function that the judge must play in evaluating scientific
and expert testimony. The Frye standards rely more on "general acceptance" which appears to be
a more vague term, subject to individual interpretation by each presiding judge. Bricklin and
Elliott (2000) concur with Krauss and Sales (2000) who suggest that Daubert standards have not
yet and probably will not make much difference to admissible evidence in the child custody
domain, largely due to the residual use of the Frye standards. Thus, the impact on PAS
admissibility remains to be seen. However, there are strong position statements offered by
sources such as Zirogiannis and Williams who contend that PAS does not meet either Frye or
Daubert criteria.
While debate within the literature continues, the court system still relies upon expert
testimony regarding such pivotal concepts as parental alienation, estrangement, and enmeshment.
It is possible for the evaluator to operate within professional and ethical guidelines by
articulating both sides in this debate, and offering cogent reasoning for the position that they
adopt. Perhaps the most ethical and appropriate position to adopt is one that sidesteps the debate
over the syndrome and instead relies on specific observations and forms of clinical evidence,
presented in an orderly fashion in the report or trial testimony, allowing the judge and trier of fact
to consider the weight and impact of these dynamics on the best interests of the child. This
approach is clear and honest, and falls within Daubert standards. Regardless of the final outcome
of the debate over syndrome diagnoses (e.g. Rotgers and Barrett, 1996), the fact remains that
experts may continue to testify as to observed family dynamics which have merit in making child
custody decisions. There may be even better empirical foundations to rely upon when using the
more sophisticated model of the "alienated child" as proposed by Kelly and Johnston (2001).
Continued research is clearly necessary, and the best informed custody evaluator will be most
helpful to the court. Remaining current on these professional writings and attending conferences
such as those sponsored by the Association of Family and Conciliation Courts will be helpful
ways to gain such knowledge.
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