Parental Alienation Syndrome

Parental Alienation Syndrome

Articles of interest


Richard A. Warshak, Ph.D.

American Journal of Forensic Psychology, Volume 19, No. 3, 2001, p. 29-59

Despite a growing literature, the term parental alienation syndrome (PAS) continues to stir controversy in child custody matters. This article draws on the relevant literature to examine the main controversies surrounding the use of the term PAS by mental health professionals. The focus is on controversies regarding the conceptualization of the problem of alienated children, the reliability and validity of PAS, and the treatment of PAS. Some attention is given to issues relevant to the admissibility of expert testimony on PAS, such as the use of the term "syndrome," the question of whether PAS has passed peer review, and whether PAS enjoys general acceptance in the relevant professional community.

Despite a growing literature, the term parental alienation syndrome (PAS) continues to stir controversy in child custody matters (1, 2). Proponents of the term believe it: 1) accurately describes a subset of children whose unreasonable alienation from a parent results, in large measure, from the influence of the other parent; 2) assists in recognizing, understanding, and treating this group of children; and 3) describes a cluster of behaviors displayed by these children which warrants the designation “syndrome.” They regard the term as helpful to courts in deciding the best interests of children and believe that testimony regarding PAS should be admissible.

Critics of PAS argue that it: 1) oversimplifies the causes of alienation, 2) leads to confusion in clinical work with alienated children, and 3) lacks an adequate scientific foundation to be considered a syndrome. They argue that the term is misused in court and that testimony regarding this diagnosis, its course, and its treatment should be inadmissible.

This article examines the main controversies surrounding the use of the term PAS by mental health professionals. It focuses on controversies in the mental health profession, including conceptualization, empirical research, and treatment issues. The article gives some attention to certain issues relevant to the admissibility of expert testimony on PAS, such as the use of the term “syndrome” and the issues of peer review and general acceptance among clinicians, but this article does not purport to provide a comprehensive treatment of this area.


Parental alienation syndrome refers to a disturbance whose primary manifestation is a child’s unjustified campaign of denigration against, or rejection of, one parent, due to the influence of the other parent combined with the child’s own contributions (3, 4). Note three essential elements in this definition: 1) rejection or denigration of a parent that reaches the level of a campaign, i.e., it is persistent and not merely an occasional episode; 2) the rejection is unjustified, i.e., the alienation is not a reasonable response to the alienated parent’s behavior; and 3) it is a partial result of the non-alienated parent’s influence. If either of these three elements is absent, the term PAS is not applicable.

Some of the controversy over PAS results from the failure to consider the second and third elements as integral aspects of the concept. Attorneys, therapists, and parents may falsely conclude that a child suffers from PAS based only on the first element—the child’s negative behavior. This reflects an inadequate understanding of the concept. Some critics of PAS make the same mistake (5-8; see 9 for Gardner’s rebuttal). They equate PAS with only the first element, attack this straw man concept, and conclude that PAS leads to confusion and misuse when they are themselves confused about the concept. Before concluding that PAS is present, in addition to the child’s alienation, it must be established that the alienation is irrational, and is influenced by the favored parent. Properly understood, a clinician using the term PAS does not automatically assume that the favored parent has influenced a child’s alienation from the other parent. Rather, the term PAS is used to describe only those children who are 1) alienated, 2) irrationally, 3) under the influence of the favored parent. PAS does not apply in the absence of evidence for all three elements.

Child psychiatrist Richard A. Gardner, M.D. introduced the term in 1985, but he was not the first to describe this phenomenon (10). In 1949, psychoanalyst Wilhelm Reich wrote about parents who seek “revenge on the partner through robbing him or her of the pleasure in the child” (11; p. 265). And in 1980, Wallerstein and Kelly described children in their research project who “were particularly vulnerable to being swept up into the anger of one parent against the other. They were faithful and valuable battle allies in efforts to hurt the other parent. Not infrequently, they turned on the parent they had loved and been very close to prior to the marital separation” (12; p.77).

Despite these earlier descriptions, it was Gardner’s detailed account of the origin, course, and manifestations of the phenomenon, along with his guidelines for intervention by courts and therapists, that captured the attention of the mental health and legal professions and stimulated the growing literature on the topic (for a review see 1, 2, 13; for a comprehensive list of publications see 14). Along with the study and elucidation of PAS, controversy remains about how to conceptualize, label, and treat this phenomenon.


To establish a new diagnostic category, we must establish that: 1) the phenomenon exists; 2) it is a disturbance or deviation from the norm; and 3) its symptoms warrant a separate diagnosis and cannot more reasonably be subsumed under a previously existing category.

Most mental health and legal professionals agree that some children whose parents divorce develop extreme animosity toward one parent that is not justified by that parent’s behavior and, to some extent, is promulgated or supported by the other parent. That such children exist is not a point of contention in the social science literature. At issue is whether we should regard this type of disturbance as abnormal, and if so, whether a separate diagnosis for these children provides significant benefits beyond already existing labels, and whether PAS is the best way to conceptualize and label this disturbance.

Is a Child’s Unreasonable Alienation Normal?

Though it might seem an obvious point, not everyone agrees that a child’s unreasonable denigration and rejection of a parent should be considered an abnormal development worthy of professional attention. One author believes it is possible that parental alienation is a normal part of growing up (15). She argued that we have no basis for regarding parental alienation as abnormal because we lack normative data from intact and low-conflict divorced families, i.e., we lack research on the prevalence of this phenomenon.

The position that it might be normal for children to be alienated from their parents is inconsistent with the scientific literature. It overlooks research on children’s adjustment in divorced families and on healthy parent-child relations in intact families.

The literature on the effects of parent conflict on children documents the harm to children who are caught in the middle of the conflict, as in situations where they are encouraged to side with one parent against the other (16). Studies of children’s attitudes about their parents’ divorce consistently reveal that most children long for more time with each parent and wish their parents would reunite (12, 17-19). One study, for example, reported that regardless of custodial status, 84% of children longed for their divorced parents’ reconciliation (17; p. 41). The desire to be with a parent is normative, not the desire to avoid a parent.

Regarding intact families, the research is clear that the type of denigration, hatred and fear characteristic of PAS is foreign to most intact families and would be considered a symptom worthy of treatment (20). Even in clinical samples with children who are enmeshed with one parent, usually the mother, the children still tolerate their father. I am unaware of any reports in the literature, nor any therapeutic programs, in which a parent in an intact family, who is not guilty of child abuse or gross mistreatment, is advised to cut off contact with the children in response to conflicted parent-child relationships. Instead, articles and books on treatment suggest strategies for helping the family understand and heal ruptured parent-child relationships.

Alternative Models of the Problem of Alienated Children

The consensus that a child’s unreasonable alienation from a parent is a problem does not extend to the issue of how to conceptualize the problem. Wallerstein finds the term PAS unnecessary and believes that the problem is subsumed under her concept of “overburdened children” who must attend to the needs of disturbed parents at the expense of their own psychological development (2, 21). She does, however, introduce the term “Medea Syndrome” to refer to vindictive parents who destroy their child’s relationship with the ex-spouse (21). Other authors conceptualize the phenomenon as a vulnerable child’s maladaptive reaction to a high conflict divorce (22). This “high conflict model” accepts the utility of a separate classification for alienated children. It uses terms such as “unholy alliances” and “extreme forms of parent alienation” in place of PAS (23; pp. 174, 202). The high conflict model differs from Gardner’s conceptualization in that greater emphasis is placed on the child’s psychological vulnerabilities and the contributions of the entire family system to the child’s alienation. By contrast, some authors place greater emphasis on the behavior of alienating parents and distinguish their destructive behavior (labeled “parent alienation”) from PAS which is one possible outcome of such behavior (24).

Kelly and Johnston expressed concern that PAS oversimplifies the causes of alienation and that Gardner’s formulation leads to confusion and misuse in litigation (25). To remedy these flaws, they drew on their considerable clinical and mediation experience with divorced families to propose a reformulation of PAS which they call “the alienated child” (hereinafter referred to as the AC model).

The AC model defines an alienated child as 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” (25). This definition retains two of the three essential elements in the concept of PAS. The free and persistent expression of negative feelings corresponds to the campaign of denigration. And the unreasonableness of the feelings corresponds to the alienation being unjustified. The third element of PAS, the influence of the alienating parent, is not part of the definition of an alienated child. The omission is deliberate. The AC model notes that the manipulations of one parent are insufficient to explain alienation because some children resist attempts to undermine their affection for a parent. Thus, other factors must play a role, and this model emphasizes the importance of multiple interrelated factors in the etiology of alienation. The AC model organizes these “alienating processes” into background factors that directly or indirectly affect the child, and intervening variables that influence the child’s response to the background factors. Examples of background factors are a history of the parents involving the children in severe marital conflict, the circumstances surrounding the separation and divorce, and the child’s cognitive capacity and temperament. Examples of intervening variables are each parent’s behavior, sibling relationships, and the child’s vulnerabilities.

Comparison of Parental Alienation Syndrome and the Alienated Child Model

In their critique, Kelly and Johnston characterize PAS as focusing almost exclusively on the alienating parent as the cause of the child’s alienation. This characterization is not entirely accurate. Even the definition of PAS refers to the influence of the other parent combined with the child’s own contributions. Gardner discusses several factors within children that lead to their joining with one parent in denigrating the other. To a lesser extent he discusses why some children are able to resist an alienating parent’s influence and maintain affection for both parents.

In addition to the contributions of the child, the literature on PAS has repeatedly and clearly identified contributions of people in addition to the alienating parent, including the alienated parent, new partners, therapists, custody evaluators, and relatives (2, 3, 26-32). Particularly in his earlier work, though, Gardner did give less emphasis to the role of the alienated parent. His recent work elaborates on the contributing behaviors of alienated parents, particularly in terms of their passivity, but he continues to regard alienating parents’ contributions as primary (33). In some respects, Gardner, who is a physician, has cast PAS in a medical model. By contrast, Kelly, a psychologist, and Johnston, a sociologist, prefer a family systems approach which gives more detailed attention to a wider range of factors without labeling any as primary.

The reformulation of PAS was also a response to its misuse in litigation. Specific concerns are that children are diagnosed with PAS who are not truly alienated or whose alienation is warranted by the history of their relationship to the alienated parent (3; pp. xx, xxviii, 13, 25, 30, 34, 35).

In some cases alienation is confused with situations in which a child prefers, or feels more comfortable with, one parent, or is significantly aligned with one parent, but still seeks to maintain a relationship with the other (25). In other cases a child may resist spending time with a parent, but is neither alienated nor acting under the influence of the other parent (13, 30, 34, 35). Such a child may exhibit hostility and apparent rejection of a parent that: 1) is temporary and short-lived rather than chronic, 2) is occasional rather than frequent; 3) occurs only in certain situations, 4) coexists with expressions of genuine love and affection, and 5) is directed at both parents (35). Situations that meet these criteria include some ‘normal reactions to divorce, developmentally normal separation anxiety, the behavior of difficult or troubled children, attempts to avoid exchanges that occur in an explosive climate, a concern about a parent’s emotional state when left alone, and situation specific reactions, such as a teenager who refuses to be around a new stepparent (34, 35).

Alienation may be justified in cases where a child is physically or sexually abused; witnesses domestic violence, frightening displays of rage, or the aftermath of violence; or suffers severe emotional abuse, neglect, abandonment, or very poor treatment by a chronically angry, rigidly punitive, extremely self-centered, or substance-abusing parent (25, 34, 35).

Gardner is clear that such situations do not constitute PAS, and he has expressed concern about the misuse of PAS (3). He gives considerable attention to distinguishing between PAS and alienation that is a response to parental abuse or neglect (36). And, without going into detail, he recognizes that children resist contact with a parent for a variety of reasons other than PAS, and that PAS is not the same as the situation where a child aligns with one parent without participating in a campaign of denigration against the other parent. The AC model gives much more specific attention to these categories than does Gardner, although articles by other authors working within the PAS framework have addressed these categories (13, 30, 34).

The AC model provides a detailed and organized description of behaviors which clarifies the distinction between alienated children and non-alienated children who show an affinity for, or strongly align with, one parent, while still maintaining a relationship with the other parent (25). In addition, the AC model gives examples of factors that can lead children to develop such affinities and alignments. By introducing specific terms to denote the categories of behavior that resemble and may be mistaken for PAS, and delineating the behaviors of children in each of these categories, the AC model may facilitate a welcome reduction in the incidence of PAS misdiagnosis and misuse. This would represent a substantial contribution that results in wiser clinical and judicial decisions.

What is unclear, however, is whether the term “alienated child” provides significant advantages over PAS. Until Gardner’s initial work on PAS, the divorce research literature made only occasional mention of children alienated from, or rejecting, a parent. The term, PAS, has proved useful in facilitating communication among clinicians and fostering numerous publications in peer-review journals. At last count there were 108 publications that focused significantly or exclusively on PAS and alienated children. Most of these were in peer-review journals, some were book chapters, and a very few were by authors who have subsequently withdrawn their support for the term PAS. Because of space considerations; the reader is referred elsewhere for a list of PAS reference citations in addition to those cited in this article (1, 2, 14).

It is possible to adopt a family systems theory of PAS, and to differentiate the various reasons for children’s rejection of parents, while retaining the familiar term PAS to denote children whose denigration and rejection goes beyond “alignment” and is not a reasonable response to the rejected parent’s behavior (30, 34).

Dropping the term “syndrome” when referring to irrationally alienated children, and limiting oneself to behavioral descriptions, does avoid legal issues surrounding the admissibility of expert testimony on PAS. But it is not clear how changing the term from PAS to “alienated child” would lead to fewer misidentifications of children who are unreasonably alienated from a parent. As with PAS, the term “alienated child” can be misapplied to children who are not alienated, or whose alienation is warranted.

In one respect, the terms proposed in the AC model may result in more confusion. Kelly and Johnston use the term “estrangement” to refer to alienation that is a realistic response to parental behavior, such as occurs in cases of parental abuse. They contrast this with “alienation” that is not a realistic response. This may be confusing because the terms “estrange” and “alienate” are synonyms.

The first definition in the dictionary under the entry “alienate” is “to make indifferent or averse; estrange” and the entry offers this sentence as an illustration: “He has alienated his entire family” (37; p. 37). The dictionary entry for “alienation of affections” is: “Law, the estrangement by a third person of one spouse from the other” (37; p.37). The first entry for “estrange” is “to turn away in feeling or affection; alienate the affections of” (37; p. 488). And the definition of “estranged” is “displaying or evincing a feeling of alienation; alienated” (37; p. 488). The use of synonyms to describe these two distinct types of alienation (reasonable versus unreasonable) invites confusion, particularly as the concepts leave the arena of mental health professionals and are used in legal circles and the popular press. Though intended to draw a clear distinction, the synonymous terms may inadvertently obscure the difference. It would be useful to have a label to refer to children whose alienation from a parent is reasonable, but “estranged” is probably not the best candidate.

Before leaving this discussion, it should be noted that neither Gardner nor Kelly and Johnston have proposed a term to refer to children whose severe alienation is not warranted by the rejected parent’s behavior, but who have come to be alienated in the absence of manipulations by the favored parent. Some aligned parents of alienated children agree that the other parent has done nothing to warrant the child’s extreme rejection, but they also deny having contributed to the alienation and profess great concern over their child’s disturbed behavior toward the rejected parent. For the sake of conceptual clarity, it makes sense to designate a term to describe this phenomenon. A possible candidate is the phrase “child-driven alienation” which has been used to describe children whose unreasonable rejection of a parent is a misguided way of coping with difficult feelings (35). The absence of a separate term for these children may be less of a problem for the AC model because it would apparently categorize such a child as alienated, with no particular assumption about the contributing factors. According to the definition of PAS, however, without the contributions of the alienating parent such a child would not fit the category of PAS.

On balance, the two formulations appear more similar than different. Both agree that some children become alienated without adequate justification, and both regard this phenomenon as a disturbance rather than a type of normal development. Both agree on how to recognize this disturbance and on how to distinguish it from alienation that is a realistic response to parental mistreatment.

Despite using different terms, both agree on the behaviors which characterize aligned parents and pathologically alienated children. In fact, the list of symptoms is nearly identical. They differ on the name given to the phenomenon, and on the relative contributions of the aligned parent. The AC model sees a greater role played by the alienated parent and the child, while recognizing the contributions of the aligned parent. According to Kelly (personal communication, 2000), this model does not regard the behavior of an alienating parent as necessary to create an alienated child, although it recognizes that it is often present. The PAS formulation sees a greater role played by the parent who is fostering the alienation, while recognizing the contributions of the child and, to a much lesser extent, the alienated parent. Both formulations rule out pathological alienation when the contributions of the rejected parent are substantial enough to warrant the child’s alienation. Overall, I believe the difference between the models is one of emphasis, and not a fundamental distinction, although this is open to dispute. Kelly (personal communication, 2000) indicated that the final version of her article with Johnston (25) will sharpen the distinctions between their model and PAS.

Both models are based on clinical experience. Both find support in the literature for some aspects of their formulation, while neither has large-scale empirical research to validate its conceptual superiority. There are substantial differences in the treatment approaches each advocates, but diagnostic terms are independent of the discovery or proposal of new treatments.

An advantage of the AC formulation is that it provides a differentiated view of the processes, factors, and behaviors in the entire family system which result in a child’s unreasonable alienation from a parent. Also, it clarifies the distinction between what is and is not alienation. An advantage of PAS is that the concept is widely known and has stimulated a clinical literature that has elucidated and refined our understanding of this disturbance. Abandoning the term would impede integration of the existing literature with future work. Also, the term PAS has the virtue of parsimony: It clearly denotes a circumscribed group of alienated children—those whose alienation is not warranted by the history of the child’s relationship with the rejected parent. By contrast, the phrase “alienated child” is ambiguous with respect to the reasonableness of the alienation, and thus requires additional descriptors (e.g.,“pathological”) to distinguish it from what the AC model calls “estrangement.”

A final caveat: Kelly (personal communication, 2000) indicated that the manuscript in press was being edited and that the final version would include revisions and refinements which address some of the points raised in the present article. Also scheduled for publication in the same journal issue (edited by Johnston and Kelly) are three articles elaborating this model’s approach to case management, custody evaluations, and therapeutic interventions. The reader is encouraged to consult these articles for the most complete and recent statement of this model.

Future work will undoubtedly result in further refinements of the AC model as well as PAS. It remains to be seen whether the AC reformulation will gain general acceptance among clinicians working with divorced families and among experts witnesses, and replace PAS, or whether future additions to the literature will support, or be compatible with, the retention and utility of the concept PAS.


The misidentification and misuse of PAS raises the issue of its reliability. Reliability, in the social sciences, means something different than legal reliability. For scientists, reliability refers to the degree to which a statistical measurement, test result, or diagnosis, is consistent on repeated trials or among different observers. A proposed syndrome, such as PAS, has high reliability if different clinicians, examining the same children, reach a high rate of agreement on which children do or do not have the syndrome. Naturally, it is not necessary for clinicians to reach one hundred percent agreement in order to qualify as having reached a scientifically acceptable level of reliability. Two doctors often disagree on a diagnosis; that is why we get second opinions. But, if the symptoms of the proposed diagnosis are too imprecise and ambiguous, or require an excessively high degree of inference on the part of the observer, the rates of disagreement may be unacceptably high. In such cases, the proposed syndrome should undergo further refinement (such as more precise definitions of symptoms) before it gains general acceptance.

The description of PAS symptoms (3), and the description of the behaviors seen in the alienated child (25), appear on the surface to be clear-cut and intelligible. We await empirical research, however, which tests the ability of clinicians to apply these symptoms to case material and agree on whether or not a particular symptom is present in a particular child. For example, Gardner lists “weak, absurd, or frivolous rationalizations for the deprecation” of a parent as one symptom of PAS. Kelly and Johnston list “trivial or false reasons used to justify hatred” as a behavior seen in an alienated child (note the close similarity between the two models). Can different observers agree on what constitutes frivolous or trivial justifications? Or is this symptom so inherently ambiguous that, after examining the same children, clinicians will disagree to a significant extent on which children’s reasons for rejecting a parent are reasonable and which should be dismissed as trivial?

To date, no study has directly measured the extent to which different examiners, with the same data, can agree on the presence or absence of PAS (or, for that matter, alienation in a child). Until a sufficiently high rate of agreement on the presence or absence of PAS is established through systematic research, the diagnosis will not attain the empirical support which is probably necessary to achieve acceptance on a par with the disorders recognized in the American Psychiatric Association’s official description of diagnoses (38). And, until such data exist, the reliability of PAS cannot be supported by reference to scientific literature. This does not mean that the diagnosis lacks reliability, any more than it meant that the diagnosis of AIDS lacked reliability prior to the publication of empirical research on the syndrome.


The validity of the concept PAS is a more complex issue than reliability. It relates to some of the issues explored in the earlier discussion of conceptualization. The central question is whether PAS accurately, adequately, and usefully describes a disturbance suffered by some children.

As is true of most, if not all, newly proposed syndromes, Gardner based his identification and description of PAS on his clinical experience. The same is true of all existing formulations of the problem of alienated children. To establish the validity of PAS, the scientific literature must demonstrate that the clinical observations that formed the basis for the initial formulation are representative of a wider population of children. There are generally two stages in this process. First, other clinicians report on their experiences related to the phenomenon, supplementing and refining the initial proposal. These reports are either anecdotal accounts of a few cases, or reports of a larger volume of cases, organized and analyzed in some systematic fashion. Second, empirical research with larger samples of subjects, standardized and systematic measures, and appropriate scientific controls tests hypotheses drawn from the clinical reports in the literature. The field of PAS study is just beginning to enter the second stage with studies in progress.

The descriptions of PAS in the clinical literature have struck a chord of recognition among divorcing parents, attorneys and mental health professionals. As we have seen, even alternative formulations of the phenomenon agree that unjustified parental alienation sometimes accompanies custody battles and that the favored parent sometimes contributes to this alienation. The concept of PAS has served to organize a volume of articles on the appropriate identification and treatment of a child suffering with this problem (1, 2). The frequency of reports in the clinical literature, and the close similarity of reported cases to Gardner’s descriptions, lends support to the validity of PAS. Reality is not determined by popular vote, but the burgeoning literature is evidence of the utility of the PAS concept, at least as experienced by practitioners in the field. As discussed below, this is relevant to the admissibility of PAS testimony.

Kopetski published two reports on severe PAS in a sample of 413 court-ordered custody evaluations conducted by the Family and Children’s Evaluation Team in Colorado (39, 40). Prior to learning of Gardner’s work, the team identified 84 cases of severe alienation that led them “independently to conclusions that were remarkably similar to Gardner’s conclusions regarding the characteristics of the syndrome.” Independent identification of the same cluster of symptoms would generally be considered strong support for the validity of a newly proposed syndrome.

Dunne and Hedrick found Gardner’s criteria useful in differentiating 16 cases of severe PAS from other cases with other post-divorce disturbances (41). Other clinicians have also found the PAS concept useful in organizing their impressions of alienated children (30-32, 42-45). Common experience and clinical cases, however, must be corroborated by systematic empirical investigations.

A 12-year study of 700 divorce families, commissioned by the American Bar Association Section on Family Law, is the one large-scale study which has delineated the phenomenon in which divorced and divorcing parents program and manipulate their children to turn against the other parent (29). This study provides some empirical support for the validity of PAS. As an early study in the field, it is heavily descriptive and the description of procedures does not make clear exactly how the data were analyzed and what procedures were used to ensure the reliability of the results. Nevertheless, because of the wealth of experience reflected in the large number of families studied, and the detailed and sophisticated analysis of the problem, this study’s observations and conclusions merit significant weight. Gold-Bikin offers this view: ‘This treatise is based on years of experience counseling families in divorce and evaluating children during custody litigation. It should provide guidance to the bar, bench, and mental health professionals in ascertaining whether a child has been intentionally brainwashed or alienated from one parent by the other parent...” (46; p. ix).

There is considerable scientific research which supports the conclusions of the ABA-sponsored study and validates key facets of PAS. Chief among these are the bodies of literature on children exposed to parental conflict (16), on programming and brainwashing (47, 48), and on children’s suggestibility (49). Numerous methodologically sophisticated studies have established that children are susceptible to accepting suggestions that an innocent adult did harmful or illegal things and then repeating these suggestions as if they were true (49). Children will even provide elaborate details of events that never occurred. Research findings on programming, brainwashing, stereotype induction, and children’s suggestibility help to explain how one parent could exert enough influence over a child to cause that child to lose affection and respect for the other parent.

Systematic empirical research is lacking when it comes to validating the specific cluster of symptoms that characterizes PAS. There is, as yet, no specification of which symptoms and how many are necessary for the diagnosis. It should be noted, however, that many of the diagnoses in DSM-IV also lack research which empirically verifies the appropriate number of symptoms necessary to make the diagnosis (50).

As discussed earlier, some clinicians believe that Gardner’s formulation of the causes of PAS oversimplifies the situation and places undue emphasis on the alienating parent. This is explored in a later section. If this criticism is correct, it may modify our understanding of the etiology of PAS, but may not undermine the validity of the PAS phenomenon itself. Gardner himself expects that the concept of PAS will be refined and elaborated by future investigators (3).


The use of the term “syndrome” in reference to alienated children has sparked heated debate. A syndrome is “a grouping of signs and symptoms based on their frequent co-occurrence, that may suggest a common underlying pathogenesis, course, familial pattern, or treatment selection.” This seems descriptive of PAS.

Some have argued that PAS does not qualify as a syndrome because not every child who is exposed to alienating behavior by one parent develops the same distinct disorder (25). This reasoning is not compelling. In medicine, including psychiatry, it is well-recognized that the same pathological agent can produce different outcomes in different individuals. This generally does not invalidate the syndrome or disorder. For example, rape may, but does not always, result in a posttraumatic stress disorder (PTSD—originally termed a syndrome). The fact that some victims survive traumas without developing PTSD does not disqualify PTSD as a proper diagnostic entity. Another example is adjustment disorder. Two children may experience the death of a parent or a divorce. One develops an adjustment disorder and the other escapes any diagnosable mental disorder. The American Psychiatric Association, which acknowledges that most of its official diagnostic categories are syndromes, specifically assumes that some disorders will “result mainly from an interplay of psychological, social, and biological factors” (51; p. xxiii). This seems to allow for a multi-factored approach to understanding. PAS, while retaining the term “syndrome.”

A greater concern is that the medical designation “syndrome” conveys an established stature and legitimacy that may be more appropriate following more rigorous empirical research. In court, the term “syndrome” may strengthen confidence in the scientific basis of the witness’ testimony and, by implication, in the value and reliability of that testimony.

An additional concern about syndrome evidence is that expert witnesses sometimes offer a collection of symptoms as a test to prove the existence of one particular causal agent, even in the absence of independent verification of the cause. In the case of PAS this would mean that, after determining that a child has the behaviors characteristic of alienated children, the expert assumes that the existence of alienation supports a claim that the favored parent must have fostered the alienation. This is clearly a misuse of PAS; by definition, the manipulations of the favored parent must be identified in order to diagnose PAS.

Mosteller has proposed that the purpose for which syndrome evidence is used should govern its admissibility (52). When an expert proffers syndrome evidence as a test of whether certain conduct has occurred, such as child sexual abuse, “the science must be of the highest quality and should satisfy the standards set out in Daubert v. Merrell Dow Pharmaceuticals, Inc.” (52; p. 468). Mosteller argues that less exacting scientific standards should apply when the expert relies on syndrome evidence “to correct human misunderstandings of the apparently unusual and therefore suspicious reactions of a trial participant” (52; p. 467).

Although PAS testimony should not be used as a test of whether the aligned parent promulgated the child’s alienation, it can provide the court with an alternative explanation of a child’s negative or fearful conduct and attitudes. Also, PAS testimony can assist the court in evaluating a child’s ability to perceive, recollect, or communicate. When PAS has been misdiagnosed, as in the case of children who are not alienated, or whose alienation is justified by the rejected parent’s behavior, expert testimony on PAS may be proffered in rebuttal.

Testimony by an expert knowledgeable about the strategies that parents use to promulgate and support alienation, the extent to which children can be manipulated to reject and denigrate a parent, the extent to which children are suggestible, the mechanics of stereotype induction, and the psychological damage associated with involving children in parental hostilities, may assist the court in determining the proper amount of weight to give a child’s explicitly stated preferences and statements regarding each parent. The expert can demonstrate that a child’s statement of preference, even when executed in an affidavit, does not necessarily reflect the history of that child’s relationship with the non-preferred parent, particularly when the child totally rejects the non-preferred parent.

Lund regards this as one of the most important benefits of PAS (30). In their study, Clawar and Rivlin determined that 80 percent of the children in their sample wanted the brainwashing detected and terminated, and there was often a substantial difference between children’s expressed opinions and their real desires, needs and behaviors (29).


The U.S. Supreme Court decision in Daubert v. Merrell Dow Pharmaceuticals, Inc. (53) provided a non-exclusive list of criteria for federal courts to consider in judging the admissibility of scientific expert testimony. Subsequent decisions, such as the Supreme Court cases of General Electric Co. v. Joiner (54) and Kuhmo Tire Co. v. Carmichael (55), and the Texas Supreme Court cases of E.L du Pont Nemours and Co. v. Robinson (56) and Gammill v. Jack Williams Chevrolet, Inc. (57) have built upon the principles of the Daubert analysis.

The application and significance of Daubertto mental health expert testimony is the subject of considerable speculation. Some commentators suggest that the Daubert decision spells the end of psychological and psychiatric testimony (58). This has not occurred. Slobogin sees little impact of Daubert on psychological testimony in criminal cases, including the admissibility of battered women and rape trauma syndrome evidence (59). In custody cases it is not clear whether trial court judges are using Daubertcriteria to evaluate expert testimony on the best interest of a particular child (60).

Shuman and Sales note the difficulty of applying Daubert’spragmatic considerations, developed for scientific testimony, to clinical testimony (61). These authors suggest that when clinically based testimony is proffered, courts “are limited to judging the qualifications of the experts and the acceptability of that testimony to other similar practitioners, resulting in nearly identical pre- and post-Daubert admissibility decisions” (61; p. 10). General acceptance in the relevant scientific community is one of the Daubert factors and is the familiar criterion originated in Frye v. United Statesfor science- based testimony (62). Many courts, though, exempt psychological syndrome testimony from a Fryeanalysis (59). With respect to syndrome testimony in criminal trials, Slobogin argues for a formulation of the Frye test that would admit testimony “that a sizeable group of professionals find plausible, based on their specialized knowledge” (59; p. 113). PAS would pass this test. Indeed, it already has (63). There is another index of the general acceptance of PAS in addition to the growing professional literature on PAS in peer-review journals. The American Psychological Association concludes its Guidelines for Child Custody Evaluations in Divorce Proceedings with a highly selective reference section titled “Pertinent Literature” (64). Three of the 39 references are books by Gardner; one is titled “The Parental Alienation Syndrome” and the other two include discussions about PAS. This could be taken to imply APA recognition of PAS as pertinent to child custody proceedings.

Zervopoulos draws on post-Daubert decisions to offer two guides for assessing the reliability of testimony that does not seem to fit the Daubert criteria (65). His analysis may be applicable to syndrome testimony. The first guide he refers to as “the applicable professional standards test” citing the decision in Gammill, which in turn quotes from Watkins v. Telmith, Inc.(66): “The court should assure that the opinion comports with applicable professional standards outside the courtroom and that it ‘will have a reliable basis in the knowledge and experience of [the] discipline’” (57; pp. 725-726). Proffering PAS testimony under the “applicable professional standards test” might involve introducing the wide body of clinical literature regarding alienated children, and the similar observations noted in the various clinical reports.

The second guide is “the analytical gap test,” drawing on the Joiner decision: “(N)othing in either Daubert or the Federal Rules of Evidencerequires a district court to admit opinion evidence which is connected to existing data only by the ipse dixitof the expert. A court may conclude that there is simply too great an analytical gap between the data and the opinion proffered” (54; p. 146). Zervopoulos explains how the “analytical gap test” might apply to syndrome testimony: “If elements of the proposed syndrome can be supported by research, those elements should pass muster under a Daubert/Robinson/Gammill analysis” (65). A similar approach is suggested by Shuman and Sales, “Kuhmo Tireand Daubertprobably will raise the level of scrutiny given to the proffers of clinical information to determine if there is science that could have been used by the clinician” (61; p. 10).

Applying this type of analysis to PAS, one could bridge the “analytic gap” with the literature on stereotype induction and on children’s suggestibility (49). An element of PAS is the persuasive influence of the alienating parent which results in a child forming an unwarranted negative opinion of the other parent. This element is supported by the literature on stereotype induction which demonstrates how children can be manipulated to form negative stereotypes and will subsequently confabulate stories about bad things the target person has done (49). Gould makes a similar point: “If parent-child verbal exchanges in alienating families can be construed as a form of suggestive interviewing, then the evaluator may attempt to identify how the parent has used specific suggestive interview techniques to alter the child’s perception of his or her father or mother” (67; p. 173).


One of the Daubert factors, and a key means of satisfying Frye’s general acceptance test, is whether the science has been subjected to peer review. The meaning and legal significance of peer review of clinical publications is debatable (61). But, it would seem fairly straightforward to determine whether or not PAS passes this criterion. Not so. Some critics imply that PAS has not passed standards of peer review because Gardner’s books on parental alienation are published by his own press (5, 6, 8). These critics also discount the peer-review status of some of Gardner’s published articles on the subject and imply that none of his work on PAS has passed peer review. These same critics omit from their analyses the many peer-reviewed publications on PAS by authors other than Gardner. An examination of the entire literature on PAS fails to support the contention that PAS has not passed peer review, and in fact strongly supports the opposite conclusion.

Although Gardner’s books are not peer-reviewed, neither are most books. He has had eleven articles on PAS pass the peer-review process in social science publications (10, 36, 68-76), two articles in legal journals (77, 78), and one invited chapter in a prestigious psychiatric reference volume whose board of editors includes many of the world’s leading experts in child psychiatry (79). Critics have tried to discount Gardner’s publications in The Academy Forum, arguing mistakenly that it does not rely on peer review (6, 8); the status of his other peer-reviewed publications has not been disputed.

In addition to Gardner’s work on PAS, there are currently 94 publications that focus significantly or exclusively on PAS and alienated children (14). Though some may question the value of peer review, or of the Frye test, as an index of the admissibility of syndrome research, there are no reasonable grounds for maintaining that PAS has not passed peer review


According to Gardner’s formulation, alienated parents are innocent of any behavior that justifies their children’s total alienation from them. If a parent’s behavior does warrant the children’s alienation, this is not a case of PAS.

When a child suffers from PAS, Gardner holds the alienating parent and the child primarily responsible. Similarly, although Kelly has clearly revised her thinking on this topic, her earlier work emphasized the contributions of the aligned parent, “The most extreme identification with the parent’s cause we have called an ‘alignment’- a divorce-specific relationship that occurs when a parent and one or more children join in a vigorous attack on the other parent. It is the embattled parent, often the one who opposes the divorce in the first place, who initiates and fuels the alignment” (12; p. 77).

Some critics argue that Gardner’s position on the etiology of PAS is incomplete, simplistic, and perhaps erroneous (6-8, 23, 25, 31). Such critics believe that the concept of PAS overemphasizes the pathological contributions of the alienating parent while overlooking other possible causes of the child’s denigration and rejection of a parent. In some cases, when the author faults Gardner for not recognizing that genuine abuse, neglect, or violent behavior can cause behavior identified as PAS, the criticism clearly reflects an inadequate understanding of Gardner’s formulation (6-9). Gardner recognizes that poor parental behavior can cause a child’s alienation; but he reserves the label PAS for the type of alienation that is not warranted by the parent’s behavior and which results from the combination of the alienating parent’s influence and the child’s own contributions.

As discussed earlier, other clinicians believe that Gardner’s formulation overlooks the importance of family dysfunction in which neither parent can be said to be psychologically healthier than the other. Lund captures this opinion: “The PAS cases that end up in therapists’ offices after a court hearing usually do not have one parent who is much more psychologically healthy than the other. From a ‘Family Systems’ perspective, the blame for PAS lies less with psychopathology of one parent than it does with the usually very high conflict between both parents and both parents’ psychopathology” (30; p. 309). Other authors concur, “Usually, PAS is not just the work of the alienating parent.. ..It is a family dynamic in which all of the family members play a role, have their own motives, and have their own reasons for resisting the efforts of others at correction” (31).

Johnston and Roseby believe that a particular type of family dynamic is responsible for certain severe alienation cases: “Rather than seeing this syndrome as being induced in the child by an alienating parent, as Gardner does, we propose that these ‘unholy alliances’ are a later manifestation of the failed separation-individuation process [the process by which a child develops psychological independence from the parents] in especially vulnerable children who have been exposed to disturbed family relationships during their early years” (23; p. 202). These authors regard the child’s vulnerability to the alienating parent as the most important aspect of some of these cases, rather than “conscious, pernicious brainwashing” by an angry parent.

In contrast, mental health professionals working with families involved in custody litigation often report clear evidence that the alienating parent is deliberately and knowingly manipulating the child (1, 2, 28, 29). Even when the manipulation is subtle, or outside the immediate awareness of the parent doing the manipulating, because of the power imbalance between parent and child. Clawar and Rivlin view the process as driven by the alienating parent (29). Kopetski’s research supports this and she regards PAS as parental exploitation of the child (39, 40). Although Kelly and Johnston do not regard the behavior of the favored parent as necessary to create the child’s irrational alienation, when such behavior is present, they too regard it as emotional abuse of the child regardless of whether the alienator consciously intends to negatively influence the child (25).

Garbarino and Scott also regard PAS as a form of psychological mistreatment of children and believe that all mistreatment of children is more likely to occur in families where the atmosphere is one of stress, tension, and aggression (80). Nicholas surveyed custody evaluators “and found significant correlations between symptoms of alienation and behaviors on the part of the alienating parent, but few links between the child’s alienation and the target parent’s behavior. This lends support to the position that the core problem in PAS is between the alienating parent and the child. This study, however, was merely exploratory and has a number of methodological limitations including a small sample of 21 completed surveys (81). Other studies report that target parents tend to be less disturbed than alienating parents, but these studies all relied on populations in which false accusations of sex abuse were present; these results may not generalize to the majority of PAS cases which do not include such allegations (82-85).

A central issue in assigning responsibility for a child’s unwarranted alienation is whether, absent the support of the favored parent, the child would have become alienated. If, for example, the flaws of the rejected parent would not normally result in the child’s total estrangement, then it may be more accurate to describe these flaws as having played a role in the child’s ambivalence rather than having caused the alienation (35). If PAS symptoms arise only after the favored parent begins to manipulate his children’s affections, and the rejected parent has not altered her treatment of the children in any significant way, this increases the likelihood that the manipulations have played a key role in the alienation; other explanations, though, are possible, such as the child exhibiting a maladaptive reaction to the divorce.

Several authors have identified how other parties, such as relatives and professionals, contribute to the alienation (2, 3, 22, 25-32). These authors have drawn attention to the damage caused by psychotherapists and custody evaluators whose intervention and recommendations reflect an inadequate understanding of PAS. Such professionals may accept as valid the children’s criticisms of the target parent, and thus the professional may perpetuate and foster PAS.

Different opinions about PAS etiology lead to different treatment recommendations. Some support the idea of conducting psychotherapy while allowing children to live with an alienating parent to whom they are pathologically tied (22). Others recommend placing the child with the parent who has the best potential for fostering the child’s healthy psychological development (3, 33, 39, 40).

Future research should help clarify which explanation gives a better account of the genesis of unreasonable parental alienation: an emphasis on the aligned parent’s behavior, or an approach which considers multiple interrelated factors without assigning priority to the behavior of any one person in the system. As our understanding of these phenomena expands, we will probably find that no one explanation can best account for every case; in some cases the contributions of the aligned parent will be paramount, while in other cases a sufficient understanding of the disturbance will require an analysis of the complex interplay of the behavior of the child, the alienated parent, and the aligned parent, along with the contributions of other people (such, a new partners, other family members, and therapists) and circumstances.


By far the most controversial issue in the PAS literature is the recommendation of enforced access between children and their alienated parents and reduction of access between the children and the parent promulgating the alienation.

In the majority of cases of moderate PAS, Gardner recommends that the court award primary custody to the alienating parent, appoint a therapist for the family, and enforce the child’s contact with the target parent through the threat and imposition (if necessary) of sanctions applied to the alienating parent (33). Such sanctions are similar to those the court would use against a parent who is in contempt for failure to pay court-ordered alimony or child support. The sanctions include a continuum from requiring the posting of a bond, fines, community service, probation, house arrest, to short-term incarceration. Some states grant courts the power to suspend a contemnor’s driver’s license or order public service duty. Turkat notes that the absence of such sanctions has allowed parents to interfere with visitation and flaunt court orders with impunity (86).

The goals of therapy with children suffering from moderate PAS are to foster healthy contact with the target parent and to assist children in developing and maintaining differentiated views of their parents as opposed to polarized views of one parent as all good and the other as all bad. One way to get children involved with the rejected parent is to take the decision about contact out of the children’s hands, reminding them of the possible sanctions against the preferred parent for resisting court-ordered contact, and thereby giving them an excuse to spend time with the target. The therapist also tries to help the children appreciate that their animosity has been influenced by programming which has undermined their ability to reach conclusions on the basis of their own direct experiences with the target. Some authors compare this aspect of treatment with the “deprogramming” that is used with cult victims to help counteract the effects of indoctrination (29, 33).

In some cases of moderate PAS, when the parent is more intensively programming the children and there is a high risk of the alienation becoming more severe, Gardner recommends a different legal approach. In such cases he recommends that courts consider awarding primary custody to the alienated parent and extremely restricted contact between the alienating parent and child, in order to prevent further indoctrination. Similarly, in the most severe cases of PAS (which, in Gardner’s experience, comprise about 5-10 percent of all PAS cases), Gardner recommends that the court remove the children from the home of the alienating parent.

Because children with severe PAS will not generally comply with court orders, and the programming parent cannot be relied upon to facilitate contact with the target parent, and because courts are reluctant to place children with a parent they appear frightened of, Gardner recommends temporary placement of the children in a transitional site before reintegrating the children in the home of the target parent. Possible transitional sites range from least restrictive to most restrictive, depending on the amount of control necessary to ensure the children’s cooperation and the alienating parent’s compliance with court orders. Such sites include the home of a relative or friend, a foster home, a community shelter, or a hospital. Gardner makes a good case for the transitional program, but he has had little direct experience with it, mainly due to courts’ general hesitance to implement it (3). Rand, however, describes some success with it (2).

In addition to serving as transitional sites, the threat of temporary placement in a foster home, community shelter, or juvenile detention center may induce children to cooperate with court-ordered visitation. With older children (ages 11-16) who refuse visits with the alienated parent, Gardner suggests the possibility of finding the child in contempt of court (4). This recommendation has met with the most opposition.

One author who objects to enforced visitation argued that a contempt finding for a child who refuses visitation is strictly punitive in nature and counterproductive (87). The concern is that such actions will reinforce the child’s hatred of the alienated parent. Instead, this author recommends that the court examine why a child resists contact with a parent and rely on family counseling and supervised visitation as a first step in repairing the child’s relationship with the alienated parent: “Instead of punishing them for their feelings, we need to work with them to help them understand the value of a relationship with their parent” (87; p. 95). Gardner, on the other hand, warns against unnecessary indulging of children’s visitation refusal (3). He believes that the best way to reverse alienation is to provide a child with direct experiences which can counteract negative programming and correct the child’s distorted perceptions of the target parent.

One problem with supervised visitation is the message it can send to a child: It can suggest that the child’s fears of the target parent are rational and that the court agrees that the child needs some sort of protection from the alienated parent. Thus, rather than increase the child’s security around that parent, it may reinforce the child’s uneasiness. The AC model makes a similar point (25).

The importance of separating the child from the alienating parent, and ensuring the child’s exposure to the target parent, is consistent with treatment methods for victims of brainwashing, including prisoners of war and members of cults. Clawar and Rivlin report on the similarities between the methods used by cult leaders to control their followers and the manipulations of alienating parents (29). Brainwashing scholars have identified the victim’s dependence on the programmer and isolation from the target as critical conditions for successful indoctrination. These conditions must be removed for effective deprogramming to take place.

The results of the ABA-sponsored study support a firmer approach to enforcing parent-child contact. The study reported, “One of the most powerful tools the courts have is the threat and implementation of environmental modification. Of the approximately four hundred cases we have seen where the courts have increased the contact with the target parent (and in half of these, over the objection of the children), there has been positive change in 90 percent of the relationships between the child and the target parent, including the elimination or reduction of many social-psychological, educational, and physical problems that the child presented prior to the modification” (29; p. 150).

Gardner’s recent follow-up study of 99 children diagnosed with PAS found a strong association between environmental modification and reduction in PAS symptoms (76). In 22 instances, the alienated child’s contact with the rejected parent was increased and contact with the alienating parent was decreased. In all 22 cases, PAS symptoms were reduced or eliminated. By contrast, only 9% of the children (7 out of 77) whose contact with the rejected parent was not increased by the court, showed a reduction in PAS symptoms. This study also provides a beginning understanding of the factors that lead alienated children to initiate their own reconciliation with the rejected parent. Further study along these lines may assist decision-makers in determining which children might not require environmental modification in order to recover from PAS. The large sample and the statistical test of significance allowed by this size sample make this an important study. Nevertheless, its limitations must be noted, chiefly that the children were not interviewed, the only informant for the follow-up was the rejected parent, and the interviews were conducted by a clinician who had formulated the hypothesis being tested.

Other treatment approaches to severe PAS have been reported in the clinical literature, but in general such approaches have met with failure. Dunne and Hedrick published a clinical study of 16 severe PAS cases (41). The court ordered a custody change and/or strict limitation of contact between the alienating parent and the children in only three of these cases. In all three cases PAS was eliminated. The other 13 cases were treated with various, less restrictive interventions, ranging from individual or conjoint therapy for the parents, therapy for the children with either the alienating parent or target parent, or the assignment of a Guardian Ad Litem. In none of these cases was the PAS eliminated. Two cases showed “some” or “minimal” improvement, nine showed no improvement, and two were worse after the interventions.

This study has significant limitations. The sample size is small. Details are not provided about the methods used to analyze clinical case material. As is typical in clinical research with small samples, no statistical analyses were conducted to document that the findings were not due to chance. Nevertheless, the 100% correspondence between elimination of severe PAS and transfer of custody does provide some evidence in support of this intervention.

Lampel analyzed clinical case studies on 18 families, out of which seven children were described as rejecting a father who had no objectively noted parental dysfunction (48). Such children could be classified as moderately to severely alienated. The therapists conceptualized the children’s rejection of the father as a phobia with hysterical features and tried two different approaches commonly used to treat phobias.

The first approach, used with six children, included individual therapy sessions with the child followed by gradually increasing times with the father both in and out of the therapist’s office. Sessions were also held for the mother, both individually and jointly with the child, for the father, and for both parents and child jointly. This approach is similar to Gardner’s recommended treatment for moderate PAS cases.

The second approach, used with one child, is similar to Gardner’s recommendation for severe PAS. The child was placed with the father for six to eight weeks while the therapist provided individual therapy sessions for the child and parents, and joint sessions with the child and father. This child was the only one of the seven children whose symptoms reduced markedly. The children whose treatment did not include placement with the rejected father experienced results varying from minor improvement to deterioration. In three cases the treatment was regarded as a clear failure. Lampel attributed the failures to the mothers’ “collusive involvement” with their children. Again, although this is a very small sample, the results support the effectiveness of placing the child with the alienated parent.

Naturally, treatment approaches to PAS will benefit from more and higher quality research. Given the limitations in the available studies, some might dismiss the current professional literature as too inadequate to serve as an authoritative guide to decisions for alienated children. But no study is free of limitations. The issue is whether the limitations render the study useless. The peer review process, though no guarantee of a study’s lasting value, is designed to weed out studies whose flaws outweigh their contributions.

Courts and clinicians face decisions about alienated children on a daily basis. These decisions can draw on the best available information, while duly noting its limitations, and thereby benefit from the experience of the families reflected in the published reports. Or the decisions can ignore this information. At this point in time, all the published findings on treatment outcomes support the effectiveness of enforcing contact between the child and alienated parent and no findings oppose this policy. When all available studies point to the same conclusion, it makes sense to pay attention to that conclusion, while allowing for the possibility that the circumstances of any single case may dictate an alternative treatment approach. Indeed, an emerging consensus among mental health professionals supports the idea that “court orders for continued contact are the cornerstone for treatment” of PAS cases (30; p. 309). Similarly, Stahl refers to “general agreement” that recommendations should include “forced consistent time between the child and the alienated parent” (88; p. 6).

But no consensus has been reached on the proposal for courts to consider a transfer of custody (as opposed to enforced contact) in severe PAS cases. Some have expressed the concern that alienated children are ill-equipped to cope with the change in custody, and that they could be seriously harmed (23). Although this possibility must be entertained, if this were a likely outcome, one would expect to see reports in the professional literature; to date there is no published documentation of such harm. Some allegations that harm has resulted from custody transfer may actually be misrepresentations promulgated by embittered litigants. Nevertheless, some clinicians advise parents of severely alienated children to accept the loss of their children while maintaining hope for future reconciliation (88).

Based on their ABA-sponsored study, Clawar and Rivlin conclude, “Caution must be exercised in judging that the point of no return has been reached. We have seen numerous cases where children have been successfully deprogrammed by making radical changes in their living arrangements—often with appropriate legal interventions” (29; p. 144). As they explain it, “There are risks incumbent in any process; however, a decision has to be made as to what is the greater risk. It is usually more damaging socially, psychologically, educationally, and/or physically for children to maintain beliefs, values, thoughts, and behaviors that disconnect them from one of their parents (or from telling the truth, as in a criminal case) compared to getting rid of the distortions or false statements” [emphasis in the original] (29; p. 141).

Large scale, objectively measured, long-term outcome studies on the effectiveness of different interventions with PAS have not yet been conducted. Until such scientific evidence is available, controversy will probably continue concerning the proper treatment of children and parents when PAS is present. And until more courts implement the proposed treatment recommendations, it is not likely that investigators will have large enough samples to conduct large-scale outcome studies.


The concept of parental alienation syndrome has received much attention in the professional literature, including articles appearing in peer-review journals which elaborate on Gardner’s original formulations. Mental health professionals and courts agree that children can suffer estrangement from a parent following divorce that is not warranted by the history of the parent-child relationship. This observation can be useful to courts dealing with a child’s visitation refusal or determining how much weight to assign a child’s stated preferences regarding custody. Although empirical research is at an early stage, the available published studies support the importance of enforcing contact between a child and an alienated parent, when the child’s alienation is not justified by that parent’s behavior.

Controversy exists, however, in conceptualizing the problem of alienated children and in using the term PAS. Those favoring the term believe it assists in understanding and treating a well-recognized phenomenon. Those opposing the term believe that it lacks an adequate scientific foundation to be considered a syndrome and that courts should not admit testimony on PAS. Critics argue that PAS is either an unnecessary or potentially damaging label for normal divorce-related behavior, that it oversimplifies the etiology of the symptoms it subsumes, and that it may result in custody decisions which fail to promote children’s welfare.

Given the volume of published references to PAS, we can expect that it will continue to be raised in custody and access litigation. Future empirical research should help resolve some of the current controversies by providing data on the reliability and validity of PAS, the effectiveness of various interventions, and the long-term course of parental alienation.

Topics for study include: 1) the ability of clinicians to reach agreement on the presence or absence of each PAS symptom and the presence or absence of PAS; 2) the factors that enable children to resist or to recover from alienation; 3) the psychological attributes of favored and rejected parents; 4) prospective studies of children who have been exposed to systematic attempts to undermine their relationship with a parent; 5) the link between unwarranted alienation and the personality and behavior of the rejected parent; 6) the incidence of unwarranted alienation in the absence of documented attempts by the favored parent to alienate; 7) comparisons of different treatment methods using adequate scientific controls, such as samples initially matched on relevant variables, raters who are kept unaware of which treatment the children received, and statistical analyses of results.

The results of such studies will yield information that should help refine and enhance our understanding of how best to help families with alienated children.


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55. Kuhmo Tire Co. v. Carmichael, 119 S.Ct. 1167 (1999)

56. E.I. du Pont de Nemours and Co. v. Robinson, 923 S.W. 2d 549 (Tex. 1995)

57. Gammill v. Jack Williams Chevrolet, 972 S.W. 2d 713 (Tex. 1998)

58. Gottesman MJ: Admissibility of expert testimony after Daubert: the “prestige” factor. Emory Law 1 1996; 43:867-876

59. Slobogin C: The admissibility of behavioral science information in criminal trials: from primitivism to Daubert to voice. Psychology, Public Policy, and Law 1999; 5:1:100-119

60. Krauss DA, Sales BD: The problem of “helpfulness” in applying Daubert to expert testimony: child custody determinations in family law as an exemplar. Psychology, Public Policy, and Law 1999; 5:1:78-99

61. Shuman OW, Sales BD: The impact of Daubert and its progeny on the admissibility of behavioral and social science evidence. Psychology, Public Policy, and Law 1999; 5:13-15

62. Frye v. United States, 293 F. 1013 (1923)

63. Kilgore v. Boyd, 13th Circuit Court, Hillsborough County, No. 94-7573 (Fla. Nov. 22, 2000)

64. American Psychological Association: Guidelines for child custody evaluations in divorce proceedings. American Psychologist 1994; 49:7:677-680

65. Zervopoulos JA: Robinson/Daubert and mental health testimony: the sky is not falling. Texas Bar J 2001; in press

66. Watkins v. Telsmith, Inc., 121 F.3d 984, 991 (5th Cir., 1997)

67. Gould JW: Conducting Scientifically Crafted Child Custody Evaluations. Thousand Oaks, CA, Sage Publications, 1998

68. Gardner RA: The detrimental effects on women of the misguided gender egalitarianism of child custody dispute resolution guidelines. The Academy Forum 1994; 38:1/2:10-13

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81. Nicholas L: Does parental alienation exist? Preliminary empirical study of the phenomenon in custody and visitation disputes. Presented at the 13th Annual Symposium in Forensic Psychology of the American College of Forensic Psychology, Vancouver, British Columbia, 1997

82. Blush GJ, Ross KL: Sexual allegation in divorce: the SAID syndrome. Family and Conciliation Courts Rev 1987; 25:1-11

83. Blush GJ, Ross KL: Sexual abuse validity discriminators in the divorced or divorcing family. Issues in Child Abuse Accusations 1990; 2:1-6

84. Blush GJ, Ross K.L: investigation and case management issues and strategies. Issues in Child Abuse Accusations 1990; 2:152-160

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87. Turkat ID: Child visitation interference in divorce. Clinical Psychology Review 1994; 14:732 742

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Richard A. Warshak, Ph.D. is a clinical and research psychologist in private practice in Dallas, Texas and consults to attorneys, mental health professionals, and families. He is a Clinical Professor of Psychology at the University of Texas Southwestern Medical Center, and is author of The Custody Revolution(Simon and Schuster, 1992), the WICAA-2 parent questionnaire, and over thirty articles on divorce and custody. His most recent publications deal with relocation, parental alienation syndrome, and overnight contact between parents and young children. His forthcoming book is Divorce Poison: Protecting the Parent-Child Bond From a Vindictive Ex (Regan Books, 2001). Email: This email address is being protected from spambots. You need JavaScript enabled to view it. ; Web:

Copyright 2001 American Journal of Forensic Psychology, Volume 19, Issue 3. The Journal is a publication of the American College of Forensic Psychology, P.O. Box 5870, Balboa Island, California 92662.


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. 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 to the court 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 in custodial considerations 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 now 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.

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, 1985a, 1987b).

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 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 explanation for the child's hostility is not applicable.

Richard A. Gardner, M.D.

Denial of the Parental Alienation Syndrome Also Harms Women

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

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 ( At the time the DSM-V committees meet, these lists will be in the proposal to include PAS in DSM-V. Elsewhere (Gardner, 2002b) I have discussed the various alternative diagnoses that therapists might use in courts that stringently refuse to accept the PAS diagnosis at this time.

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.

Differential Diagnosis of the Three Types of Parental Alienation Syndrome

The Campaign of Denigration Minimal Moderate Formidable
Weak, Frivolous, or Absurd Rationalizations for the Depreciation Minimal Moderate Multiple absurd rationalizations
Lack of Ambivalence Normal ambivalence No ambivalence No ambivalence
The Independent-Thinker Phenomenon Usually absent Present Present
Reflexive Support of the Alienating Parent in the Parental Conflict Minimal Present Present
Absence of Guilt Normal guilt Minimal to no guilt No guilt
Borrowed Scenarios Minimal Present Present
Spread of the Animosity to the Extended Family of the Alienated Parent Minimal Present Formidable, often fanatic
Transitional Difficulties at the Time of Visitation Usually absent Moderate Formidable or visit not possible
Behaviour During Visitation Good Intermittently antagonistic and provocative No visit, or destructive and continually provocative behaviour throughout visit
Bonding with the Alienator Strong, healthy Strong, mildly to moderately pathological Severely pathological, often paranoid bonding
Bonding with the Alienated Parent Strong, healthy, or minimally pathological Strong, healthy, or minimally pathological Strong, healthy, or minimally pathological


Richard A. Gardner, M.D.


The American Journal of Forensic Psychology 20(2):5-29, 2002.

Richard A. Gardner. M.D.

The parental alienation syndrome (PAS) is a disorder that arises in children in the context of child-custody disputes. It is the result of the combination of the programming (brainwashing) of children by the alienating parent and the children’s own contributions to a campaign of denigration against the alienated parent. A central factor operative in the children’s contributions is their empowerment, most often by the indoctrinators, but occasionally by the passivity of the targeted parent. In addition to these intrafamilial factors, extrafamilial factors are also operative, especially the legal system and mental health professionals. This article focuses on the ways in which all of these empowerment factors operate in the etiology, development, and perpetuation of the parental alienation syndrome.

The parental alienation syndrome (PAS) is a disorder that arises almost exclusively in the context of child-custody disputes (1-17). In this disorder, one parent (commonly referred to as the alienator, the alienating parent, or the PAS-inducing parent) induces a program of denigration against the other parent (commonly referred to as the alienated parent or the target parent). However, this is not simply a matter of "brainwashing" or "programming" because the children contribute their own elements to the campaign of denigration. It is this combination of factors that justifiably warrant the PAS diagnosis. When bona fide abuse/neglect is present, then the PAS diagnosis is not applicable. The primary symptoms of the PAS are:

1) Campaign of denigration

2) Weak, frivolous, and 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

8) Spread of the animosity to the extended family and friends of the alienated parent

In this article, I focus on the empowerment of children that is typically seen in the context of the PAS. Empowerment of children is operative in each of the eight symptoms. Such empowerment is provided primarily by the alienating parent who encourages the children to vilify the target parent in such a manner that traditional rules of good conduct and respect are ignored. The empowerment may be aided by the alienated parent if that parent is passive by personality or becomes passive because of fear of worsening the situation if he (she) were to more actively attempt to constrain the PAS child. Furthermore, there are a variety of extrafamilial factors that contribute significantly to the child’s empowerment. The most important of these is the legal system at every level at which the family becomes involved. Here I will describe specifically how these empowerment factors operate in both the intrafamilial and extrafamilial realms.

The Role of the Alienating Parent in PAS Children's Empowerment

The primary source of PAS children’s empowerment is the programmer who empowers the children in the context of the campaign of denigration. The programmer writes the scripts, and the children recite them. There are repeated rehearsals. In fact, the programmers know well that "booster shots" are frequently required if the programming is to be maintained. They know well that healthy and benevolent input is the best antidote to the poisons injected into the child’s brain in the process of PAS indoctrinations. Empowerment can be seen in each of the eight primary symptoms of the PAS. Here I describe how this operates for each of the eight symptoms.

With regard to the campaign of denigration, the alienating parent may say to the target parent in front of the child:

"Why don’t you listen to her? "Can’t you see that she hates you and doesn’t want to be with you?"

"Can’t you hear what she’s saying to you? She’s saying that she finds you despicable."

"Have you no respect for your children’s wishes? She doesn’t want you at the school play. Can’t you get that into your thick skull?"

The child is empowered to mimic and parrot the programmer’s disparaging and denigrating messages, and there are no consequences to the child for the ensuing displays of disrespect and denigration. Rather, the most absurd rationalizations for the alienation are never questioned. Instead of confronting the child with the absurdity of these reasons, the alienator may make such comments as "I respect his (her) feelings" and "It’s important for her (him) to speak her (his) mind."

With regard to the weak, frivolous, and absurd rationalizations for deprecation, the child may give as reasons for never wanting to have contact again with the alienated parent: "He used to belch a lot at the dinner table," "He once said, `shit,’" and "She makes me go to bed too early." PAS children are not told by their alienators that their reasons are illogical and preposterous. They are exposed to such reactions in all other realms, e.g., "No, the earth is not flat," "Your sister did not make you hit your baby brother," and "Your teacher is not to blame for your not doing your homework." Yet, in the realm of the PAS professions, such constructive feedback is not given.

With regard to the child’s lack of ambivalence, children in a healthy home are taught that everybody is a mixture of things they like and things they do not like, even one’s parents. This principle is ignored when it comes to the comments about the victimized parent. PAS children are led to believe that there is one individual in this world who is an exception to that principle. The victimized parent may come to be viewed as the incarnation of all the evil that ever existed in the history of the world. The alienated parent may be compared to Adolph Hitler; Saddam Hussein; and Judas, the betrayer of Jesus Christ. Accordingly, any grief one can cause such a despicable individual is justified and supported. This contributes to the child’s empowerment.

With regard to the "independent-thinker" phenomenon, inculcating this notion is an intrinsic part of the programming. Alienators traditionally are accused of indoctrinating the campaign of denigration into the children. Typically they deny such participation, and the children pick up this defense and claim vociferously that their maltreatment of the victimized parent is all their own idea. They know that the programmer wants them to profess such independence, and they fear that if they do not do so, they may lose the affection of the alienating parent. This also contributes to their sense of empowerment. Hence, they profess that they are not passive weaklings parroting reflexively the campaign of denigration. Nor are they puppets or marionettes, automatically professing hatred for the victimized parent. Rather, they are intelligent, independent thinkers who have a mind of their own and have come to these conclusions free of any influence from the programming parent. This delusion, too, contributes to their sense of empowerment.

The reflexive support of the alienator also contributes to a sense of empowerment. This is in line with what is referred to in psychiatry as the identification-with-the-aggressor phenomenon. Weak people can gain strength by joining in with more powerful individuals, even people whom they recognize as noxious and despicable. The child basically subscribes to the principle: "If you can’t fight ’em, join ’em." The alienator is recognized as the more powerful force. Accordingly, the child reasons that joining the alienator will provide protection against being victimized like the targeted parent, obviously a stronger position. In contrast, to join the alienated parent may result in one’s being victimized oneself, obviously a weaker position.

With regard to the absence of guilt, PAS children are taught to be psychopathic. They exhibit neither sympathy nor empathy for the feelings of the targeted parent. This defect enables them to perpetrate their campaign of denigration without any feeling of low self-worth that is an intrinsic part of guilt. The absence of such guilt, then, facilitates implementation of the campaign of denigration and the associated empowerment that comes with it. The guiltless acting out of anger also produces a sense of empowerment, no matter how despicable the cause. Probably the best examples of this in the 20th century were Adolph Hitler, Joseph Stalin, and Saddam Hussein.

The borrowed scenarios that are incorporated into the PAS campaign of denigration are the ammunition that enhance the efficacy of the campaign. The children use words that would not generally be found in the vocabulary of youngsters that age. They may not even know what the words mean, but they do know that their use ingratiates them to the programmer and can have the effect of justifying the alienation. A four-year-old girl says, "I never want to see my daddy again because he penetrated me." The child does not have the faintest idea what the word penetrated means. She obviously learned this term from her mother who has incorporated a sex-abuse accusation into the PAS campaign of denigration. The child recognizes that this statement is going to get significant attention from all the adults around her, especially the child protection people, the police, and the sex-crimes investigators in the prosecutor’s office. Never before did this little girl enjoy such notoriety. Such words indeed give the child power!

Last, when the campaign spreads to the victimized parent’s friends and extended family, the child becomes empowered to treat with disrespect and disparagement an ever-growing number of adults. The child who says to a loving grandmother over the telephone, "I hate you grandma. I never want to see you again" and then hangs up the phone knows that there will be no repercussions for such maltreatment of a grandparent. In fact, each time the child does this, the programmer provides support and even rewards. This empowers the child to "tell off" powerful adults. It provides a fulfillment of the fantasy of the little kid beating up all the big guys in the neighborhood or the single soldier, with one sword, fighting off a whole army.

The Role of the Alienated Parent in PAS Children's Empowerment

In most cases of PAS, the disorder is primarily the result of the programming of the children by the alienator. However, there are occasions when the victimized parent contributes to the development of the disorder. My experience has been that most alienated parents are true victims and are doing nothing to deserve the grief that has been visited upon them by their children’s PAS symptomatology. However, there are some, a small percentage, who unfortunately contribute to the children’s empowerment. My experience has been that passivity on the part of the alienated parent has been the most common factor. Such a targeted parent may be afraid to provide corrective confrontations or implement traditional disciplinary measures for their PAS children lest their responding anger intensify even further the campaign of denigration. The children’s responses may then become incorporated into their campaign of denigration, e.g., "He said that my mother wasn’t telling me the truth," "She said that I’ve been brainwashed by my father," and "He gave me time out, just because I wouldn’t talk to him all afternoon." Such a parent may also fear that such negative feedback will come to the attention of the court and be viewed by the judge as a violation of the court’s restriction from disparagement of the other parent to the children.

There are some who claim that victimized parents (especially men) have been "asking for it" and thereby deserve their victimization. This to me is the equivalent of saying that women who have been raped are generally "asking for it." There are some who claim that narcissism contributes to such victimization. Those who make this claim are usually basing their conclusion on clinical impressions. On occasion, they may refer to an MMPI report in which the word narcissism appears among the sea of other characteristics which the patient presumably exhibits on the basis of the test finding. My experience has been that such parents’ diagnosis of narcissism was not justifiable with the utilization of the more stringent criteria for narcissism to be found in DSM-IV (18). I am not saying that I have never seen a narcissistic PAS targeted parent. What I am saying is that it is not a common problem for them, especially with regard to their contribution to the PAS. But even if some of the victims are narcissistic, that does not justify the conclusion that they thereby justify being so victimized. Some claim that targeted parents contribute to their children’s hatred of them by their seemingly intrusive behavior and preoccupation with seeing their children. Those who view the situation in this way are generally insensitive to the plight of the alienated parent, whose frustration and impotent rage may be formidable. Their intrusiveness and obsessive preoccupation is a reaction to their exclusion, not the primary cause of it.

I have been seeing PAS children since the early 1980s. The only pattern that I have seen in which I can justifiably conclude that the alienated parent has contributed to the children's empowerment and campaign of denigration has been passivity. To date I have not seen any other factors. I am not claiming that other factors do not exist; I am only claiming that I have not seen them frequently enough to warrant my making any general statements about such contribution. It is this passivity, however, that facilitates the PAS children’s empowerment.

The Role of the Legal System in PAS Children's Empowerment

The parental alienation syndrome (PAS) is primarily a product of the adversary system. The system is based on the theory that the best way to find out "the truth," when opposing sides have different opinions on a particular issue, is for each side to present its position to an impartial party or tribunal (judge, group of judges or jury). Presumably, the truth will emerge from the presentation of the opposing arguments. The system was originally designed to determine whether an accused party did indeed commit the illegal act that was alleged to have been perpetrated. Although it may be a useful system for making decisions in that realm (and I have my doubts about that as well), it is clearly not applicable for finding out who is the better parent when they are involved in a child-custody dispute. Yet, that is the system within which such disputes are presumably resolved in the United States and many other countries. Elsewhere, I have described in detail the deficiencies of this system for this purpose (2, 6).

I have been actively involved in child-custody litigation since 1963, a span of approximately of 38 years. I am convinced that this method for resolving custody disputes does families more harm than good. One of my books is completely devoted to the psychologically detrimental effects on children and their parents of their embroilment in this system (2). I believe that if the courtroom were completely unavailable for the adjudication of such conflicts, and if the family were to have no other place to turn but themselves for resolution of these conflicts, that, on the whole, more good than harm would be done. Of course, there would be some children who would be completely unprotected from their warring parents and might be used as ropes in the parental tug of war. However, this number would be small compared to the much larger group of children who would be protected from the depravities of the adversary system. Furthermore, parents too would be better off. Although battling it out on their own is certainly psychologically traumatic, using the courtroom as the battlefield is far more traumatic.

Pertinent to this article is the empowerment that the legal system-- especially the adversary system--provides children, an empowerment that complements the empowerment provided by the alienating parent. It is common in such disputes for the judge to appoint a third attorney, an attorney who represents the child’s interests. Sometimes this person is referred to as the child’s attorney and sometimes as the guardian ad litem. Although the terms maybe be used synonymously, most often the courts make a sharp differentiation between the two roles.

The person who is designated as the child’s attorney functions in a manner very similar to the attorneys who are representing each of the parents. Such attorneys do not have unilateral access to the court. They cannot speak with the judge without the presence of the other attorneys. Furthermore, at the time of the trial, they may put witnesses on the stand and conduct both direct and cross-examinations in a manner similar to the parents’ attorneys.

In contrast, the guardian ad litem is the judge’s designee and has direct access to the judge. The guardian has free access to all parties, that is, attorneys from both sides and the parents, as well as the child. It is a freer and more flexible role. In the courtroom the guardian ad litem is less likely to be permitted to bring in witnesses and conduct examinations, although I have seen some limited permission to engage in such a role in the courtroom.

The Guardian Ad Litem

I am ambivalent about guardians ad litem and the utilization of yet another attorney in adversarial proceedings. Because of my preference for mediation, arbitration, and other methods of dispute resolution that do not involve adversarial proceedings, I am reluctant to support a program that invites yet another attorney into the battle. Besides the extra expense, it is likely that another attorney will just add to the intensity of the conflict. However, I have found that the guardian ad litem can be particularly useful to the impartial examiner (and even to an adversary evaluator) in the course of the evidence-gathering phase of the evaluation. The guardian ad litem can generally be relied upon to assist in obtaining documents that a parent might have been hesitant to provide or to enlist the court’s assistance in getting reluctant parents to cooperate in the evaluation. The guardian ad litem, even more than the impartial examiner, is allowed direct communication with the judge and can thereby speed the process of the evaluation and obtain information that might not be so easily acquired.

However, it is important that the judge and the attorneys (the people who are involved in choosing the guardian ad litem) be certain that the person chosen is familiar with the PAS. To select a guardian who is not familiar with the PAS increases significantly the risk that the PAS will become entrenched. Attorneys who serve as guardians in child-custody disputes must reorient themselves regarding what they have been taught in law school: that they must zealously support their client’s position, even if they have no conviction for it. Guardians ad litem must appreciate that their clients are children and their judgment regarding what is really in their best interests may be somewhat compromised.

A guardian ad litem who is not familiar with the PAS may cause serious psychological damage to children suffering with this disorder. A guardian ad litem who is not familiar with the causes, manifestations, and proper treatment of children with PAS may prove a definite impediment in the course of their treatment. The guardian who takes pride in supporting what children profess they want is likely to perpetuate the psychopathology of children suffering with PAS. The guardian must recognize that PAS children need to be forced into doing things that they profess they do not want to do. They must appreciate that PAS children want excuses to have contact with their alienated parent. Most PAS children secretly welcome excuses that will enable them to have contact with the alienated parent, especially when the disorder is in the mild and moderate categories. They need to say to the alienator; "I really hate going to visit, but I’m scared that if I don’t Mr. X or Ms. X (the guardian) will get us in trouble with the judge." In order to do this, the guardian must "switch gears" and unlearn certain principles learned in law school regarding being a zealous supporter of one’s client’s requests and demands. Guardians must be ever aware that the client is a child, not an adult.

And guardians must also be ever aware that the client is just not any child, but a child with a PAS. If these considerations are taken into account, then the guardian will be comfortable doing just the opposite of what the client requests. The guardian ad litem must appreciate that the children’s best interests are not served necessarily by doing what the child professes, but doing what is really best for the child. The two might not be the same. A competent and ethical guardian will say to the court:

"I do not believe that it is in the children’s best interests for the court to go along with their request that they have no contact at all with their mother (father). It serves their best interests that they be forced to see the alienated parent in spite of their protestations, even their vigorous and hysterical protestations."

Such a guardian must be comfortable with the children’s criticisms and must be willing to be used as the excuse for the children going to the allegedly hated parent:

"I really hate that lawyer. He says I must visit my father. I really hate my father. You know, Mommy, I love you, and I don’t want to go there, but he makes me go there."

In this way, the guardian serves as a vehicle for assuaging the child’s guilt over disloyalty to the alienator, disloyalty implied by any willingness to visit the targeted parent.

Guardians who do their work properly will help educate judges and attorneys who are not familiar with the PAS. They will impress upon the adversary attorneys and the court the importance of ordering the kind of special therapeutic programs necessary for the treatment of PAS children (13, 16). The guardian should then serve to help implement the special court-ordered treatment program. Sometimes the guardian can serve as an intermediary between the court-appointed neutral PAS therapist and the court. I am not recommending here that the guardian serve merely as a messenger. Rather, the guardian would clarify for uncooperative parents the legal consequences of their recalcitrance to facilitate visitation and add clout to the therapist’s warnings and threats.

The Child’s Attorney

My experience with guardians ad litem has been mixed: some do what is best for the children and ignore their PAS professions, but most reflexively support them no matter how pathological their demands. In contrast, my experience with children’s attorneys has been uniformly tragic (and I have no hesitation using that word). Without exception, they vigorously and zealously support their client’s position, ignoring the fact that their clients are PAS children whose claims are just the opposite of what is good for them, just the opposite of what is in their best interests. My attempts to get them to see that they are corrupting their clients, empowering them to a degree that is significantly pathological, falls on deaf ears. Typically, a six-year-old PAS client will say to the alienated parent over the telephone: "If you come here and try to take me to your house, I’m going to call my lawyer," "If you don’t let me go home right now, I’m going to call my lawyer," and "If you give me time out, I’m going to tell my lawyer." In testimony, I have spoken along these lines with regard to the children’s attorney and sometimes even about the guardian ad litem:

"I am sure that Ms. X would not support the children’s demands that they not go to school, not visit the pediatrician, and not take their immunization shots. I am sure that Ms. X would not support the children if they wanted to shoot their mother with a gun, poison her food, or throw their infant brother into the swimming pool. Yet, Ms. X is supporting vigorously the children’s desires to do equally self-destructive things--destructive to themselves and destructive to others--when she argues that the court should respect their desire not to see their mother."

All this generally falls on deaf ears because lawyers are so deeply committed to the notion that a lawyer must zealously support the client’s position. We see here an excellent example of the detrimental effects on children of the empowerment provided by the legal system. It is a form of corruption of young minds, a corruption that empowers them to not only wreak havoc on innocent alienated parents, but compromises themselves as well, because the deprivation of a loving parent cannot but produce significant psychopathology, both at present and in the future.

The Child Advocate

In recent years, the term child advocate has taken on a special meaning. Traditionally, the term referred to an attorney who served the children in the course of litigation. Some jurisdictions differentiate between the child advocate and the guardian ad litem; other jurisdictions do not. These differences sometimes relate to whether the individual is allowed to conduct cross-examinations in the courtroom. Recently, there has emerged a group of individuals, most often not attorneys, who refer to themselves as child advocates. These people may or may not have had formal training in any of the traditional mental health disciplines. They generally are those who wave the banner, "Believe the children," and take at face value everything and anything children say.

Child advocates gravitate, especially, to sex-abuse evaluations, where they hold stringently to the position that "children never lie," especially in the realm of sex abuse. They sanctimoniously preach that we should "believe the children," and they look down condescendingly on those who claim that children alleging sexual abuse should not necessarily be believed. A false sex-abuse accusation is a common spin-off of the PAS and so this position can be extremely detrimental in PAS situations when the likelihood that the accusation is true is very small.

My experience has been that some of these individuals are using their seemingly benevolent advocacy of children in the service of venting rage upon men, and they are, for the most part, derived from the group of overzealous women who have found this field to provide a wonderful opportunity for this outlet (19, 20). Others are poorly trained and/or simpleminded and believe that they are indeed joining a noble cause. Whatever the motivations of these individuals, examiners do well, these days, to be wary of engaging the services of someone whose primary label is "child advocate." To date, I have not seen one child advocate in the context of a child-custody dispute who has been useful to the children whose position they advocated. And this has been especially the case when a false sex-abuse accusation has emerged as a spin-off from the PAS. Rather, they have provided children with pathological empowerment and often entrench PAS delusions and even sex-abuse delusions (19, 21).


Judges play an important role in the empowerment of PAS children. Obviously judges have the power to delegate and transmit their power down to children via pathways that are easily traceable. For example, it is routine for judges to warn parents that they should strictly refrain from criticizing one another in front of the children. This admonition may often be verbally transmitted in the course of a custody hearing and it is routinely incorporated into court rulings. Although well meaning, this advice is misguided. All of us, whether or not our parents are divorced, should have as accurate a view as possible of our parents -- both their assets and their liabilities. Children tend to identify with and unquestioningly accept their parents’ characteristics. They operate on the principle: "If it’s good enough for them, it’s good enough for me." When young they swallow the whole package, so to speak, indiscriminately identifying with many qualities that are not in their best interests. As they grow older, healthy children learn to accept parental qualities that are desirable and tolerate or reject those that are not.

Subtle forms of denigrating communications to the children are quite common among PAS indoctrinators. They are ostensibly complying with the judge’s order not to criticize the other parent to the children. In fact, they may profess, somewhat sanctimoniously, "I told him that there are things about his father that I could tell him that might cause him to hate his father, but they’re too terrible to talk about, so I strictly refrain from mentioning them." A child returns home from a week’s visit with mother. The father asks, "So what did you do this week with your mother?" The child answers, "She took me to Disney World." One father responds, with a tone of excitement and a look of surprise on his face, "She took you to Disney World?" The message imparted is this: "You are certainly lucky to have had such a wonderful vacation." Another father responds with a tone of incredulity and a facial expression of disbelief, "She took you to Disney World?" The response implies that the mother is somehow stupid or depraved if she could choose such a vacation. We see here how the same words were used by both of these fathers, but obviously entirely different messages were communicated. The first gets across the message that the child is indeed lucky to have such a loving mother. The second gets across the message that God must have shortchanged this child to have given him a mother who would subject him to such an abominable vacation. There is no way that a judge’s order is going to effectively prohibit such communications. And if a judge believes that a supervisor is going to protect the children from such communications, then the judge is naïve. The supervisor will not only be unable to protect the children from many of the PAS indoctrinating communications, but will serve as an intrusive element that cannot but compromise the healthy elements in the relationship between the indoctrinator and the PAS child, programming notwithstanding.

My experience has been that it is rare for a PAS indoctrinator to comply with the judge’s order not to criticize one another in front of the children or criticize the other parent to the children. Overtly and covertly, they typically violate it. In fact, in all of my experiences with PAS families, I have never seen one indoctrinator who has been deterred by such an order. Nor have I seen such violating parents ever punished by a court for such violation. However, I have seen many situations in which the victimized parent will strictly comply with it. They not only fear that the court will sanction them for confronting the children with the programmer’s lies, but fear that their confrontations will be incorporated into the children’s campaign of denigration and add yet more ammunition to be used against them. Sometimes this failure to criticize the children relates to a general passivity problem on the part of the victimized parent. Elsewhere, I have elaborated on this possible contribution to the PAS on the part of the alienated parent (16). The net effect of this is that the children become free to indulge themselves in their vilification of the victimized parent. They know that the alienating parent will not comply with the court order to refrain from criticizing the alienated parent in front of and to the children. And they know also that such expressions of denigration will not be constrained or restricted by the alienated parent for the aforementioned reasons. We see here, then, how this misguided order contributes to the development and perpetuation of the PAS as well as the pathological empowerment of PAS children.

Another way in which judges contribute to the empowerment of PAS children results from their deep-seated reluctance to change child custody, even when PAS is clearly present. Indoctrinators who are primary custodial parents know well that judges are extremely reluctant to change the status quo, especially when it comes to custodial change. I am not claiming that judges never do this; I am only claiming that my experience has been that custodial change in PAS cases is uncommon, and victimized parents usually have a hard uphill fight to get the court to transfer custody to their homes. The courts believe the children’s PAS lies and delusions, comply with them, and thereby empower them. And the parade of mental health professionals will discourage the court from such transfer lest these "tender little souls" become upset. Indoctrinating parents know this well and this situation encourages them to continue with their indoctrinations. And this, then, gives alienators free reign with regard to the programming process and thereby empowers the children to continue denigrating the targeted parent even more.

A related phenomenon is the absolute refusal of judges to impose sanctions on PAS adolescents. Communities generally have facilities for incorrigible youngsters. Some are placed in psychiatric hospitals and others in juvenile detention centers. Yet I have never seen a case where such a disposition has been ordered for a PAS child, no matter how despicable the behavior. I generally do not recommend that such youngsters be placed in such centers for long periods. Rather, I am certain that a visit for an hour or two would serve to sober most of them up and reduce significantly their ongoing disparagement of the victimized parent.

PAS children need excuses to give the programmer for reducing and even refraining from their PAS campaigns. They need to say to the programmer: "I really hate going there, but I’d better go because the judge said if I don’t, he’ll put me in a juvenile detention center" or "I really hate him, but I’m only going there because I know the judge will punish you if I don’t." If the judge’s warnings are frivolous and empty, they will have no effect. If, however, the mother and the youngster know that the judge is serious about threats of repercussions, then change is likely to take place. Unfortunately, I have great trouble getting judges to provide meaningful threats, threats with conviction. I am often criticized for the use of the word threat. Similarly, I am often criticized for even mentioning the term juvenile detention center to these children. All of us need threats. If you do not pay your electric bill, they turn off the electricity. If you do not pay your mortgage, you may lose your house. There have to be consequences in life. People must be accountable. PAS children sidestep this important life principle, so important in a civilized society. They are encouraged to be uncivilized because they do not have accountability. Their empowerment corrupts them.

My experience has been that in about 10 percent of PAS cases, a false sex-abuse accusations emerges (3, 21, 22, 23). And such accusations provide children with enormous power. In the mid-1980s, when I first started to speak about this phenomenon, there was general incredulity on the part of judges. Over the years, courts have become increasingly aware of this common depravity. Although less likely to accept as valid such accusations, my experience has been that judges rarely dismiss entirely the accusation but, even when they find no evidence for sex abuse, will still recommend supervised visitation. One of the most famous examples of this is the Woody Allen case. The court did not find Woody Allen guilty of having sexually abused Mia Farrow’s daughter; however, supervised visitation was still ordered.

A judge who has a reputation for protecting us from perverts, who puts them behind bars if there is even the slightest suspicion that they have sexually abused our children, will generally be viewed with approval and gratitude. In contrast, the one who has allowed even one pervert to roam the streets may not be reappointed or reelected. Under these circumstances, judges will often take no chances. There are judges who have openly made statements along these lines: "If there is one scintilla of evidence, no matter how remote, that this person sexually abused a child, I will do everything in my power to remove him (her) from society." In the service of this goal, constitutional protections of due process are ignored. The principle of our founding fathers that a man is innocent until proven guilty is basically ignored. In these cases, a man is guilty until proven innocent. The principle that it is preferable that a hundred guilty men be set free than one innocent man be incarcerated is reversed to: rather a hundred innocent men be found guilty than one guilty person be allowed to go free. Such judges get positive feedback from hysterical parents and thereby enhance the likelihood of reappointment or reelection. One result of this is that little children become empowered to put adults in jail. Elsewhere, I have elaborated on this point (19).

The Role of Child Protection Services in PAS Children's Empowerment

Mention has been made of the false-sex-abuse accusation spin-off of the PAS. Essential to the success of such a maneuver is the child protection service. Although we certainly need child protection services (CPS), especially because child abuse (including sexual abuse) is quite common, there is no question that the people who work in such agencies are often overzealous and err on the side of concluding that the accused party is indeed guilty. Although things have progressively become better over the last 15 to 20 years, my experience has been that the people who work in such agencies are still likely to be overzealous and err on the side of concluding that the abuse took place. They still use anatomical dolls, body charts, and other diagrams that are sexually suggestive and contribute to the child’s making comments that lead to the conclusion that sexual abuse has taken place. And although they claim that they no longer use leading questions, all of the videotapes I have seen of their interviews (and I do not hesitate to use the word all) are replete with leading questions. Although CPS evaluators routinely profess that they do not use leading questions--because they know intellectually that they are supposed to claim that--they generally do not know what a leading question is and still provide questions that plant seeds and elicit sexual answers (24).

It is not simply naiveté that is operative here. The more such investigators conclude that sex abuse has occurred, the more demands they can make for money to support their services. Anyone who claims that these people are overreacting and that there are not as many sexually abused children as they profess is viewed as not being properly protective of abused children and may possibly have some kind of pedophilic tendencies him- or herself. Accordingly, a multimillion dollar, if not billion dollar, industry has grown. This industry has provided a powerful weapon for PAS indoctrinators. In fact, in the history of divorce conflicts, it is probably reasonable to say that no greater weapon has ever been placed in the hands of an angry parent than the sex-abuse accusation. The whole industry is out there that will send "gangbusters" to the house within minutes in order to take action against the alleged perpetrator.

Divorcing parents know well that murdering the hated spouse will generally result in formidable repercussions for the murderer. However, such an angry parent can easily bring about a state of living death for the hated spouse, within a few minutes, by simply picking up the telephone and calling the local child protection people. Even when the accusation is ultimately considered to be "unfounded," the stigma remains--often throughout life. What good parent would want their child to visit the home of another child whose parent was accused of sexual abuse?

The child protection workers empower children enormously. Many wave the flags "Children Never Lie" and "Believe the Children." Every utterance, no matter how preposterous is given credibility, especially if the utterance relates to sex abuse. People are taking meticulous notes and even videotaping these utterances, no matter how ludicrous and removed from reality. The child was never taken so seriously. The child never had so much attention. And all this creates pathological empowerment. All the child needs to do is to say a word about a "bad touch" or about how a parent "touched my private place" and everyone in the room stops and freezes. Immediately, with pencil and pad in hand, the comments are memorialized for posterity. Photocopies are duly made and these are distributed to lawyers, the court, therapists, and all other concerned parties. I have seen cases in which satanic ritual abuse was allegedly perpetrated. Weekends were spent with the child’s going around town pointing to the various sites where the satanic abuses allegedly took place. And it was not only the parents who accompanied the child but child protection people, the so-called "child advocates," and "experts" on satanical ritual abuse. It is rare for children to receive such empowerment. Elsewhere, I have elaborated on this problem (19).

The police, also, typically become involved. A child’s interrogation by police, prosecutors, and those in the sex-abuse units, may be somewhat frightening. However, the interviews are also enormously ego-enhancing. All these important and powerful people are paying dutiful attention to every bit of dribble that flows out of the child’s mouth. I have seen situations in which these people will give such children police badges and make them "junior cops" after providing their sex-abuse "disclosures." Again, more empowerment. I am not saying that all sex-abuse accusations are "dribble." What I am saying is that most, but not all, that arise in the context of child-custody disputes are false.

From the outset, the child is assured that the inquiry has nothing to do with any crimes he (she) may have committed. Rather, the child is told that he (she) is providing valuable assistance to the police in bringing to justice a pervert who, incidentally, happens to be the child’s own father, mother, stepfather or stepmother. The child comes to learn that the sex-abuse accusation can be a powerful weapon in its own right, and the accusation need not be initiated by the programmer. I have come across children who have said: "If you punish me, I’m going to call Mary Jones at Child Protection and tell her that you sexually abused me again." Unfortunately, this will work, and it may actually freeze the accused parent. The child knows that Mary Jones is likely to take seriously any accusation, no matter how preposterous. And Mary Jones may claim that the law requires her to initiate, yet once again, an investigation, even though she herself may have little if any conviction by then for the validity of the allegation. The sex-abuse "team" descends upon the home and the child enjoys enormous attention and notoriety. Once again, we see here how the child abuse industry provides these children with empowerment.

The Role of Therapists in PAS Children Empowerment

My experience has been that the vast majority of therapists have contributed formidably to the pathological empowerment of PAS children. Child therapists traditionally take the stance that they are more sensitive than others to the needs of children, more respectful than others of their desires, and are therefore more likely to provide them with the support for their professions and requests. A common problem here is that they often do this to the point where they lose sight of the injudiciousness of such "respect" and compliance. They often sanctimoniously profess that they really respect what children want, unlike parents and others in the world who do not really respect children. This holier-than-thou attitude often contributes to the empowerment of PAS children, especially their campaigns of denigration and often false sex-abuse accusations.

Some therapists take the position that their role is to support the position of the child no matter how injudicious. In the service of this principle, they blind themselves to the preposterousness of the professions of their child patients, even when they are as ludicrous as those often seen in a PAS campaign of denigration. And this, of course, contributes to their pathological empowerment. A common situation is the one in which the PAS programmer selects a therapist who is not likely to get input from the other parent. In fact, they will screen therapists and will engage only the services of those who will join in with them against the victimized parent.

Some therapists are naïve enough to agree at the outset that they will see the child with the understanding that the treatment will be kept secret from the alienated parent. I have seen many cases in which the victimized parent did not learn for weeks, months, and even years about the "treatment." Competent child therapists know that it is important for the therapist to have access to both parents, divorce notwithstanding. Incompetent therapists are generally not appreciative of this important principle and contribute thereby to PAS empowerment.

Some take the position that their role is to respect the child’s "perceptions." No matter how pathological the perception, no matter how divorced from reality, no matter how delusional, the therapist still rolls on with the child’s perception. And if the perception is that the alienated parent is despicable, abusive, dangerous, neglectful, etc., then the therapist accepts that as valid and does not question it. In fact, questioning it would be viewed as an antitherapeutic maneuver, because it would allegedly demean the child and get across the message that the therapist is not taking the child seriously. Competent therapists recognize that one of the purposes of therapy is to correct misconceptions in a benevolent way, in a way that does not necessarily demean the child. And this can certainly be done. The analogy to one’s own children is applicable here. A loving parent needs to criticize children continually, but the love and affection that lies beneath the criticisms are felt by the child, and they are not demeaned. The child recognizes that the correction of misperceptions is an important developmental experience and necessary for the child’s well-being.

Such "respect" for the child’s "perceptions" regarding the target parent is different from every other experience a child has in life, experiences in which other people express incredulity and disagreement with perceptions that have absolutely nothing to do with reality. And when the sex-abuse spin-off is operative here, then the result of such respect for the child’s "perception," can contribute to the promulgation of a false sex-abuse accusation. Some of these therapists, in the course of the treatment of these allegedly sexually-abused PAS children, repeatedly tell the child that the environment in the office is "safe." In fact, I have seen situations in which the facility has a room that is referred to as the "safe room." The implication there is that the alleged perpetrator is so relentless in the desire to abuse the child that some kind of protection on an ongoing basis is necessary.

I have seen situations in which the alleged perpetrator is incarcerated and yet the child is still told that he (she) is now "safe." This cannot but engender in the child the notion that the accused party is still dangerous and still likely to perpetrate sexual depravities. This approach cannot but engender unnecessary fears, hypervigilance, and anticipation of sexual dangers when there is no evidence for such. It is an antitherapeutic maneuver promulgated under the guise of being therapeutic. It also has the effect of empowering the child because it gets across the message that there are people all around who are constantly protecting the child from the alleged perpetrator.

There are therapists who subscribe to the principle that one of the purposes of treatment is to release feelings and "let it all out." They tell the PAS children that they must be angry at the victimized parent and that one of the purposes of the treatment is to let out the anger. The child is encouraged to punch dolls, bang with sticks, and even scream profanities. This is allegedly therapeutic. What it does is to entrench ever more deeply in the child’s brain circuitry the notion that the alienated parent is indeed a despicable individual. It encourages more acting out against that parent and strengthens the campaign of denigration. It also has the effect of producing the pathological empowerment that comes with the acting out of anger.

The same therapists who are ever proclaiming that they subscribe to the aforementioned principles of respect for the child’s professions, respect for the child’s perceptions, etc. generally have their limits regarding such alleged respect. They would not "respect" the child who refuses to go to school on an ongoing basis. They would not respect the child who wants to take drugs, drink alcohol, run away from home, or throw an infant sibling into the swimming pool. Yet, they fully respect the child’s campaign of denigration against the alienated parent and fully respect the derivative false sex-abuse accusation. They would not respect the child’s destruction of their own property, attempts to physically assault them personally (especially with weapons), or to burn down their offices. They would not respect the child who comes in with an animal that defecates on their rugs or attempts to bite them. They would not respect the child who comes in with a baseball bat and tries to wreak the waiting room. Yet, they respect the same child’s similar, if not identical behavior, when it is directed toward others, especially a victimized parent in a PAS.

The Occasional Role of the Alienated Parent in The PAS Children's Empowerment

I have seen many reports in which the examiners claim that the alienated parent has contributed to his or her grief. Some have claimed that they are "asking for it." I have never seen this happen. I consider targeted parents to be true victims. The comment is reminiscent of those who claim that women who are raped are "asking for it." Some claim that the alienated parent is overly intrusive, thereby provocative, and so contributes to the children’s animosity. I have not seen this to be the case. Rather, I find these parents to be suffering with profound feelings of helplessness and they repeatedly try to gain access to their children, which then becomes labeled as intrusiveness and even harassment. Some have claimed that victimized parents are narcissistic and have an inordinate sense of entitlement. I have never yet seen one such parent satisfy DSM-IV criteria for the Narcissistic Personality Disorder.

What I have seen, however, is passivity that has played a role in the empowerment of PAS children and the development of the PAS. Typically, the parents are fearful of imposing traditional disciplinary measures, lest the children become even more antagonistic. They are fearful that any criticism of either the children or the alienating parent will result in their being referred to as "liars" and this will become incorporated into the children’s campaign of denigration. This situation is worsened by courts typically warning divorcing parents never to criticize one another to the children. Accordingly, the parent who confronts the children with the fact that they are being programmed may be accused of violating court orders. Accordingly, the parent fears taking action and becomes viewed as an easy "pushover," as someone who can be degraded, mocked, and ignored with impunity and without consequences. Such is the humiliation suffered by the targeted parent. This passivity, so often imposed upon the targeted parent, contributes to the children’s empowerment and the intensification of their PAS symptomatology.


We are seeing, then, an empowerment of children unequaled in history. Many grandparents have said to me, with regard to their PAS grandchildren, comments along these lines: "When I was a kid, if I spoke to my father that way, he’d beat the daylights out of me," "It’s too bad they can’t whip kids anymore. A good whipping would cure that kid in five minutes," and "In my day kids would never dare to speak to their parents that way. They’d get the strap." I am not suggesting that we go back to physically abusing children. I am suggesting that we just go back to the point where reasonable and humane disciplinary and punitive measures are implemented so that children are not free to denigrate and humiliate with impunity their PAS-alienated parents. There must be accountability. There must be consequences. Without accountability and consequences, there cannot be a civilized society. PAS children are being programmed to be uncivilized and even to be psychopathic.

Such empowerment of children results in defective reality testing, narcissism, impairment in the ability to feel sympathy and empathy, and disrespect for authority that cannot but spread to nonparental figures, such as teachers and employers in the future. PAS children are often viewed as "spoiled brats" and justifiably so. My experience has been that such corruption of these children in their youth contributes to their becoming social misfits as adults.

I have described here how pathological empowerment is provided not only by parents of PAS children, but the whole network of mental and legal professionals who are involved in PAS litigation. The PAS is a product of the adversary system. Unfortunately, the system that is available to bring about alleviation of PAS symptomatology generally results in a deepening of the disorder adding, thereby, unnecessary grief to people who are already suffering painfully.


1. Gardner, RA: Recent trends in divorce and custody litigation. Academy Forum (a publication of the American Academy of Psychoanalysis) 1985; 29(2):3-7

2. Gardner, RA: Child Custody Litigation: A Guide for Parents and Mental Health Professionals. Cresskill, New Jersey: Creative Therapeutics, Inc., 1986

3. Gardner, RA: The Parental Alienation Syndrome and the Differentiation Between Fabricated and Genuine Child Sex Abuse. Cresskill, New Jersey: Creative Therapeutics, Inc., 1987

4. Gardner, RA: Child custody. In Basic Handbook of Child Psychiatry, edited by Noshpitz, J.D., Vol. V, pp. 637-646. New York: Basic Books, Inc., 1987

5. Gardner, RA: Judges interviewing children in custody/visitation litigation. New Jersey Family Lawyer 1987; 7(2):26ff

6. Gardner, RA: Family Evaluation in Child Custody Mediation, Arbitration, and Litigation. Cresskill, New Jersey: Creative Therapeutics, Inc., 1989

7. Gardner, RA: Legal and psychotherapeutic approaches to the three types of parental alienation syndrome families: when psychiatry and the law join forces. Court Review 1991; 28(1):14-21

8. Gardner, RA: The Parents Book About Divorce, Second Edition (paperback). New York: Bantam Books, Inc., 1991

9. Gardner, RA: The Parental Alienation Syndrome: A Guide for Mental Health and Legal Professionals. Cresskill, New Jersey: Creative Therapeutics, Inc., 1992

10. Gardner, RA: The detrimental effects on women of the misguided gender egalitarianism of child-custody resolution guidelines. The Academy Forum (a publication of the American Academy of Psychoanalysis) 1994; 38(1/2): 10-13

11. Gardner, RA: Recommendations for dealing with parents who induce a parental alienation syndrome in their children. Issues in Child Abuse Accusations 1997; 8(3): 174-178.

12. Gardner, RA: Recommendations for dealing with parents who induce a parental alienation syndrome in their children. Journal of Divorce & Remarriage 1998; 28(3/4):1-23.

13. Gardner, RA: The Parental Alienation Syndrome, Second Edition. Cresskill, New Jersey: Creative Therapeutics, Inc., 1998

14. Gardner, RA: Differentiating between the parental alienation syndrome and bone fide abuse/neglect. American Journal of Family Therapy 1999; 27(2)

15. Gardner, RA: Family therapy of the moderate type of parental alienation syndrome. The American Journal of Family Therapy 1999, 27(3): 195-212.

16. Gardner, RA: Therapeutic Interventions for Children with Parental Alienation Syndrome. Cresskill, New Jersey: Creative Therapeutics, Inc., 2001

17. Gardner, RA: The parental alienation syndrome: Sixteen years later. The Academy Forum (a publication of the American Academy of Psychoanalysis) 2001; (in press)

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

19. Gardner RA: Sex Abuse Hysteria: Salem Witch Trials Revisited. Cresskill, New Jersey: Creative Therapeutics, Inc., 1991

20. Reactive Backlash and Overreactive Backlash. News for Women in Psychiatry (a publication of The Association of Women Psychiatrists), 16(2):3-7,24.

21. Gardner, RA: Psychotherapy with Sex-Abuse Victims: True, False, and Hysterical. Cresskill, New Jersey: Creative Therapeutics, Inc.,


22. Gardner, RA: True and False Accusations of Child Sex Abuse. Cresskill, New Jersey: Creative Therapeutics, Inc., 1992

23. Gardner, RA: Protocols for the Sex-Abuse Evaluation. Cresskill, New Jersey: Creative Therapeutics, Inc., 1995

24. Gardner, RA: Leading stimuli, leading gestures, and leading questions. Issues in Child Abuse Accusations 1992 4(3):144-155.

about the author

Richard A. Gardner, M.D. is Clinical Professor of Child Psychiatry at the College of Physicians and Surgeons, Columbia University, in New York City. In addition, he is in private practice in Cresskill, New Jersey. He is the author of numerous books and articles on various aspects of forensic psychiatry. His most recent books related to this article: The Parental Alienation Syndrome, Second Edition (1998) and Therapeutic Interventions for Children with Parental Alienation Syndrome (2001).

Family Therapy of the Moderate Type of Parental Alienation Syndrome

The American Journal of Family Therapy. 27:195-212, 1999

Department of Child Psychiatry, College of Physicians and Surgeons,
Columbia University, New York, New York, USA

Each of the three types of parental alienation syndrome (PAS) warrants a different therapeutic approach. Because PAS is a family problem, family therapy is usually warranted-separation, divorce, and even litigation notwithstanding Furthermore, formidable modifications of traditional family therapy approaches are warranted if there is to be any chance of success in the treatment of PAS families. Especially important is the full support of the court for the therapist's stringent and authoritarian methods necessary for the treatment of these families. Without such support, the therapist is not likely to be successful. Described here are the special family therapeutic techniques warranted in the treatment of families in which the PAS is of the moderate type.

Parental alienation syndrome (PAS; Gardner, 1985, 1986, 1987a, 1987b, 1989, 1992a, 1998) is a psychiatric disturbance that arises in the context of litigated child custody disputes, especially when the dispute is prolonged and acrimonious. There are three types of parental alienation syndrome, the differential diagnosis of which is crucial if one is to properly treat the disorder. In Table 1 the primary manifestations of each of the three types are delineated. In this article I focus on the treatment of the moderate type. Because PAS is a family problem, a family therapy approach is warranted--separation, divorce, and litigation notwithstanding.


When working with PAS families, it is important that only one therapist be used. This is not a situation in which the mother should have her therapist, the father his therapist, and the children their own. Such a program, although seemingly respectful of each party's individual needs, is not likely to work for PAS families. Such fractionalization reduces communication, is likely to set up antagonistic subsystems within the family, and will probably intensify and promulgate the pathological interactions that contribute to PAS. Therapists who treat PAS children individually are likely to be "led down the garden path" and seduced into believing that their patients have indeed been subjected to the humiliations that PAS children are so skilled at describing. The same principle holds for therapists who work individually with the programming parent. The therapist needs input from both parents. The therapist needs input from the victimized parent to learn directly how inappropriate and ludicrous the children's complaints are, and the therapist needs direct experience with the alienator to observe that parent's manipulations directly. It is only by treating all family members, individually and in varying combinations, that one can get a full appreciation of a PAS family psychodynamics.

Differential Diagnosis of the Three Types of Parental Alienation Syndrome




Primary Symptomatic Manifestation




Campaign of denigration Minimal Moderate Formidable
Weak frivolous, or absurd rationalizations for the deprecation Minimal Moderate Multiple absurd rationalizations
Lack of ambivalence Normal ambivalence No ambivalence No ambivalence
Independent-thinker phenomenon Usually absent Present Present
Reflexive support of the alienating parent in the parental conflict Minimal Present Present
Absence of guilt Normal guilt Minimal to no guilt No guilt
Borrowed scenarios Minimal Present Present
Spread of the animosity to the extended family of the hated parent Minimal Present Formidable, often fanatic
Transitional difficulties at the time of visitation Usually absent Moderate Formidable, or visit not possible
Behavior during visitation Good Intermittently antagonistic and provocative No visit, or destructive and continually provocative behavior
Bonding with the alienator Strong, healthy Strong, mildly to moderately pathological Severely pathological, often paranoid bonding
Bonding with the alienated parent Strong, healthy, or minimally pathological Strong, healthy, or minimally pathological Strong, healthy, or minimally pathological



It also is important that the treatment be court ordered and the therapist have direct input to the judge. This can often be facilitated by the use of a guardian ad litem or a child advocate who has the opportunity for direct communication with the court. The alienating parent must be fully aware that any obstruction to the treatment or interference with the visitation process will be immediately reported to the judge, either by the therapist directly or through the guardian ad litem. The court must be willing to impose sanctions for recalcitrants--for example, fines, transfer of custody, or even jail. If the court is unwilling to impose such sanctions, then the therapy is likely to prove futile.

Therapists who work with PAS families must be comfortable with authoritarian approaches. There is no place in such treatment of patiently waiting for patients to gain insight. This is especially true when the therapist is dealing with the alienating parent. The therapist who cannot switch roles and be comfortable with a stringent, authoritarian approach should not be treating such families. Furthermore, the therapist must be comfortable with a treatment program in which there is a modification of traditional confidentiality. Specifically the therapist must have free access to reveal, at his or her discretion, any and all information disclosed in the treatment to specific outside parties, such as attorneys on both sides, the guardian ad litem, and the court. Without such freedom, the therapy is likely to prove futile.


Before embarking on the treatment, the therapist must have a clear idea regarding exactly what the nature of the court's support will be. All of the possible sanctions should be spelled out clearly in a court order. As the court's impartial therapist, direct communication with the judge is possible in order to clarify this issue. Such therapists must know exactly what threats they can use to lend support to their suggestions, instructions, and even manipulations, I have no hesitation using the word threats. Life is filled with threats. If one doesn't pay one's household bills, services are discontinued. If one repeatedly does not show up for work, one ultimately gets fired. Without threats there would be no organized civilized society. And traditional therapy has its threats; for example, "If you don't pay your bills, I'm going to seriously consider discontinuing treatment," and "If you don't cooperate with regard to taking the medication I'm prescribing, I don't think I can be of help to you." It is in the treatment of PAS families that threats are crucial. Empty threats are not only a waste of time but also compromise the treatment. Threats that have little if any possibility of implementation provide the therapist with a reputation of being weak and impotent and significantly compromise the likelihood that the treatment will be effective. In order for the threats to have clout, the therapist must be court ordered. Otherwise, the therapist's threats are going to be meaningless.

Generally, the threats necessary to use in the treatment of PAS families lie on a hierarchy, and the therapist does well to pose them in order from mildest to most severe. A mild threat might simply be that the therapist will report the parent's lack of cooperation to the court. A higher level threat might involve a court-ordered reduction in the payments the alienated parent is required to provide to the alienator. Of course, there are limitations to this threat in that one cannot leave the programming parent destitute or incur such privations that the children will not be cared for properly. Obviously, this threat will be less efficacious for the wealthy than for the poor. Also, this threat is not viable when the alienated parent is not giving any money at all to the alienator. Sometimes a fine for each failure to produce the children will work; sometimes a more ongoing type of financial withholding may be necessary to help the alienator cooperate. The threat of permanent transfer of the children to the primary custody of the victimized parent (with the alienator then having visitation) can sometimes be invoked.

The highest level threat is jail. In recent years, fathers have commonly been jailed for failure to fulfill financial commitments, but I have no personal experience with mothers being jailed for failure to fulfill their commitment to enforce the visitation of the children with their fathers. Although I have repeatedly recommended such a ruling or rulings to courts, I have thus far not been successful in convincing judges that this is the only "treatment" that is likely to work. One could start with house arrest, in which the alienator would be put to jail if discovered out of the home during a prescribed period, such as the time frame of the court-ordered weekend visitation. If this does not prove efficacious, then the next step would be the more traditional house arrest, in which there is random telephone monitoring by the police and an electronic ankle band that communicates with the local police station. The next step is more formal incarceration in the local jail. Usually short periods suffice to help the alienating parent "remember" to produce the children at the assigned times.


Alienators in the moderate category of PAS will often find their own individual therapists with whom they develop a mutual admiration society in which the therapist (consciously or unconsciously) becomes the programmer's champion in the conflict. Parents in this category have a way of selecting therapists who will support their antagonism toward the targeted parent. My experience has been that this is much more often the case for female alienators than male alienators. Most often, such programming mothers choose a female therapist-especially a woman who is generally antagonistic toward men Typically, the mother's therapist has little, if any, contact with the father and so deprives herself of the opportunity to hear his view of the situation. When such therapists do meet with him, they typically will be hostile and unsympathetic. Accordingly, the mother and the therapist often develop a folie-à-deux relationship. However, when one, considers the fact that the programming parent already has a folie-à-deux relationship with the child, the addition of such a therapist justifies the term folie-à-trois for the arrangement. Although the court may not wish to prohibit the mother from seeing this therapist, it does well to prohibit the children from being "treated" by her (as mentioned, the therapist is rarely a man). Even if the court were to order the mother's therapist to stop treating her, it is likely that she will find another therapist who will naively support her in the programming process. Accordingly, I do not generally recommend that the court order a cessation of the mother's treatment with the therapist with whom she is pathologically involved. The court should order the mother to see the court's therapist, even though her maneuvers to obstruct the court-ordered therapy may be significantly supported by her own therapist.

Typically, PAS indoctrinators in the moderate category will either refuse meaningful involvement in the special treatment program described here or, if they profess such interest, will ultimately be uncooperative, obstructionistic, and do everything possible to sabotage the therapy. They may profess interest and cooperation, but their behavior attests to just the opposite. PAS-inducing parents "can create a facade of wanting peace and cooperation, while covertly continuing the campaign of aggression and sabotage."

The therapist should do everything reasonably possible to find some healthy "insider" on the alienator's side of the family. Sometimes the alienator's mother, father, or sibling can serve in this capacity. One is seeking a person who is aware that the alienator is "going too far" with regard to the animosity that she or he harbors toward the spouse and is fostering the children's alienation. If a good relationship existed between the victim's parents and the alienator's parents prior to the separation, the therapist might prevail on the victim's parents to speak with the alienator's parents. Sometimes family meetings in which both parents and all four grandparents are present can be useful. The alienator's mother can be a very powerful therapeutic ally if the therapist is able to enlist her services. I cannot emphasize strongly enough the importance of the therapist's attempting to find such an ally on the alienator's side of the family. Such individuals can sometimes bring programmers to their senses and effectively prevail on them to "loosen up" and appreciate how detrimental their maneuvers are to the children. Many parties who are appreciative of the programming parent's injudicious behavior take the position of "not wanting to get involved." In some cases, these individuals fear that if they do not support the programmer's position they, too, will become the targets of the same rage that is directed toward the victimized parent. The therapist does well to attempt to have access to such people and to impress on them that their neutrality may be a terrible disservice to the children. I have no problem generating guilt in such individuals if it will serve the purpose of facilitating their involvement in the therapeutic process.

Most of the alienators in the moderate category of PAS are not receptive to insight therapy in which they delve into the reasons for their exaggerated animosity. There are, however, some PAS indoctrinators in this category who may indeed involve themselves meaningfully in the therapeutic process. At the most superficial level, one tries to get them to appreciate the importance of the other parent's role in the children's upbringing and to recognize that their PAS-inducing manipulations, although causing grief to the victimized parent, are also contributing to the children's psychopathology. Many PAS inducers have been so blinded by their rage that they do not appreciate this obvious effect of their campaign of denigration and exclusionary techniques.

Sometimes the alienator's rage stems from jealousy that the vilified parent has a new involvement and the alienator does not. Such jealousy is a contributing factor to the program designed to exact vengeance on the former spouse by depriving the hated spouse of the children, his or her most treasured possessions. Another factor that often contributes to the PAS campaign of animosity is the alienator's desire to maintain a relationship with the former spouse. Inducing PAS in a child cannot be accomplished in one single maneuver. It requires ongoing monitoring, adjustments, and "the injection of booster shots." The tumult so engendered guarantees ongoing involvement, accusation and counteraccusation, and attack and counterattack. Most people, when confronted with a choice between total abandonment and hostile involvement, would choose the acrimonious relationship. The PAS inducer demonstrates this point well. To the extent that one can help such a parent pick up the pieces of her or his life and form new involvements and interests, one is likely to reduce this element in the rage. The most therapeutic experience such a parent can have is meeting a new companion with whom she or he becomes deeply involved and forms a strong relationship.

Economic factors may contribute to a PAS mother's anger. Divorced women generally suffer more financial privation than their husbands. This is a common contributing factor to the rage that fuels PAS indoctrinations. If the therapist has compelling reasons to believe that the mother has been "short-changed" in the settlement, then professional input (from accountants and knowledgeable lawyers) may be warranted. In such cases the therapist does well to inform the court (preferably by letter, with copies to the parents and their attorneys) that he or she has good reason to believe that the property and financial settlement has not been fair, that the mother's unnecessary privations are contributing to the anger that is perpetuating the PAS, and that a more egalitarian settlement would prove therapeutic for ail concerned. Therapists must appreciate that they are not accountants or financial lawyers and that what may appear to the mother to be an unfair settlement may, in fact, not be. Accordingly, the therapist should not come to any final conclusions on this matter but should leave this to the proper experts.

Maternal overprotectiveness is commonly a factor in producing PAS in the children. Such mothers view the world as a dangerous place, and the father may be viewed as a potential source of danger to the children. Therapeutic alleviation of the overprotectiveness, then, may prove useful in reducing such a mother's propensity to engender PAS in her children. If the mother has sexual inhibition problems that result in her projecting her sexual impulses in sum a way that she promulgates a false sex abuse charge, this problem must be addressed as well (Gardner, 1996). All sources of anger, both related to and unrelated to the spouse, should be investigated--especially if they result in anger being channeled into the vengeance and rage directed toward the victimized parent.

I have been involved in many cases in which mothers in the moderate category suddenly decide that they .want to move to another state. They suddenly become "homesick," after many years of comfortable adjustment in the locale where the children were raised. Some suddenly decide that they want to remove themselves (and the children, of course) from the scene of the custody conflict (including the whole state) and "start all over" or "find themselves" at some remote place. A few claim better job opportunities exist in another state. Some claim a new romantic involvement with a man who resides and works at this remote location. The therapist should examine carefully the reasons for such sudden decisions to relocate. Of course, there are women who do indeed meet a new person, and involvement with that individual may be possible only if they relocate. And there are indeed women who do have better job opportunities elsewhere. However, when a PAS is present, the therapist should conduct a detailed inquiry into the request and be very suspicious regarding the justification for the move. When it is obvious that the decision is yet another exclusionary maneuver in the context of a PAS, then the court should be advised to inform the mother that she is free to leave the state at any time she wishes (as is done for any adult); however, she should recognize (as if she does not appreciate it already) that the children will remain in their original location with the despised spouse as the primary caretaker. In recent years, courts have become increasingly receptive to such requests by mothers (far less so when the request comes from the father) and this, I believe, is an unfortunate trend. Elsewhere (Gardner, 1998) I have commented on this phenomenon.


The court's therapist must have a thick skin and be able to tolerate the shrieks and claims of impending maltreatment that PAS children often profess. Doing what children profess they want is not always the same as doing what is best for them. Therapists who believe that they must "respect" their child patients and accede to their wishes will be doing PAS children a terrible disservice. These same therapists would not "respect" a child's wish to refuse a polio shot, yet they will respect the child's wish not to visit with a parent who shows no significant evidence for abuse, maltreatment, or neglect. (Again, I take the opportunity here to repeat what I have repeatedly emphasized previously [Gardner, 1992a, 1998], that when bona fide abuse is present, the PAS diagnosis is not applicable.) The therapist does well to recall that prior to the separation the children were likely to have had a good, strong relationship with the targeted parent and that strong psychological ties must still be present. Accordingly, the therapist should view PAS children's professed animosity as superficial and designed to ingratiate themselves with the alienator. To take the allegations of maltreatment seriously, is a terrible disservice to PAS children. It may contribute to an entrenchment of the PAS and may result in years of, if not lifelong, alienation.

Similarly, when a fabricated (as opposed to bona fide) sex abuse allegation has been introduced, if the therapist is convinced that it is false (especially after thorough evaluation [Gardner, 1995]), then he or she does well not to allow the children to dwell on these allegations. Typically over time such false allegations become elaborated on, and new allegations arise when the earlier ones do not result in the targeted parent being totally removed from access to the children. Accordingly, it is antitherapeutic to listen to these. Rather, it is therapeutic to say, "That didn't happen! So let's go on and talk about real things, like your next visit with your father." A false sex abuse allegation may become an intrinsic part of the PAS and may become a formidable additional dimension. However, it is beyond the purposes of this article to discuss in detail the incorporation of sex abuse allegations into the PAS. I have discussed this important dimension, however, elsewhere (Gardner, 1987a, 1991, 1992a, 1992b, 1993a, 1993c, 1995, 1996, 1998).

Therapists must appreciate that PAS children need them to serve as an excuse for visiting with the victimized parent. When "forced" by the therapist to visit with the alienated parent, PAS children can say to the programmer that the therapist is mean, cruel, and so on, and that they really do not want to see the despised parent, but the therapist "makes them." And the judge should appreciate that he or she, too, can serve this function for the children. With a court order, they can say to the alienator, "I really hate my father (mother), but that stupid judge is making me see him (her)." I cannot emphasize this point strongly enough. Not appreciating this principle is one of the most common errors made by therapists involved in the treatment of PAS children. Specifically, they fail to appreciate that the children actually want to be forced to visit so that they have an excuse to do so, and such an excuse necessarily involves complaints about the therapist's coercions and cruel manipulations. PAS children are far more likely to make such excuses when a bona fide threat of sanctions has been ordered by the court and the children have been apprised, to a degree commensurate with their age and level of understanding, that there will be court-ordered painful consequences to the alienators if they do not visit. Under such circumstances, the programming parent might then start to pressure the children to visit in order to protect her- or himself from the consequences of being in contempt of court. Whereas previously the indoctrinators' professions to the children that they wanted them to visit the victimized parent were feigned and hypocritical, when meaningful sanctions have been ordered by the court, the indoctrinators may now really "mean business" when they urge the children to visit, because they appreciate that the court is serious and that they will actually suffer serious consequences (including house arrest and even incarceration) if the children do not visit. Accordingly, it is not only the children who are likely to respond to threats of court sanctions but also the alienator.

The following interchange took Place in the context of a discussion I had with Sally, a 6-year-old PAS child who refused to visit with her father for a whole weekend (as ordered by the court) but agreed to see him for ,hour or two. This decision, of course, represented a compromise between her two parents' requests of her.

Gardner: What would you do if the judge said that if you don't see your father for a full weekend, he'll stop your mother's money for that week?

Sally: I wouldn't see him. I'd get a job and give her all the money I have.

Gardner: Suppose he said that if you don't see him, he'll stop your mother's money forever. She'd have no money. What would you do?

Sally: All of us (Sally and her two brothers) would get jobs.

Gardner: Suppose the judge said that if you don't see your father for a full weekend, he'll put your mother in jail for that weekend?

Sally: My mother said she'd go to jail for me if I was that uncomfortable with him and didn't want to go.

Gardner: Suppose the judge said, "I'll keep her in jail unless you go and I'll keep her in jail until you go."

Sally: I guess I'd go!

This is a classical PAS interchange. The child is only "uncomfortable" and has only a vague sense that does not want to go visit with her father. Without any specifics, she is willing to suffer for herself and her mother these Draconian restrictions. However, at the bottom line, when told that her mother would remain in jail as long as she refused to visit with her father, Sally readily submitted. Often PAS children need this excuse. They need to be able to say to their programmers that they hate the victimized parent and are agreeing to visit only to protect the indoctrinator from court sanctions. The children need to be aware of such court threats of sanctions and even knowledge of sanctions that have actually been implemented. Often, the threats are not enough, and an implemented sanction can get the alienator and children to appreciate the fact that the court means business. If the court is not willing to order such sanctions, and if the court is not willing to impose them if court warnings are not complied with, then the therapist's position is considerably weakened, and the total treatment program is likely to prove futile.

To justify visiting the vilified parent, PAS children may embrace various excuses. These rationalizations, they hope, will convince their programmers to approve their visiting the estranged parent. One PAS child said to me "The only reason I see him is for his money. When I go there he gives me money." Another child said, "My father said he won't give us any money if I don't go and see him. So that's why I'm going. If I stop going there, we'll all starve to death."

The therapist must also appreciate that older children may promulgate the programming down to younger ones. My experience has been that the oldest children are the first to exhibit PAS manifestations and then the disorder progressively travels down to the younger ones. Accordingly, at any time one may see varying degrees of alienation among the children, even to the point where the eldest may be diagnosed as severe, a middle child as moderate, and the youngest child as mild. Waldron and Joanis (1996) also described this phenomenon. The older children are especially likely to program the younger children during visits with the targeted parent. The programmer thereby can rely on her or his, accomplice to "work over"' the younger ones when in the "enemy" camp. These older children are justifiably referred to as "ringleaders." They may wind the other children up to be disrespectful, disruptive, obstructionistic, and to engage in a wide variety of other activities that serve to act out the alienator's anger.

Because of the separation, the programming parent has less access to the targeted parent. An effective way to enjoy release of such anger is to program the children to act out the alienator's rage in the home of the alienated parent. The older siblings may not only take on the role of surrogate programmer but also may assume other parenting roles. This comes about because the vilified parent is often viewed as an incompetent, and so someone has to fill the vacuum. Or, the targeted parent may be viewed as dangerous, and so someone has to protect the younger sibling(s). In the course of such "parenting" the older child may repeat verbatim the programmer's PAS indoctrinations; for example, "This isn't a safe place," "You've got to keep an eye on him [the alienated father]," "There he goes again, giving us less food than he gives his girlfriend." Some older PAS children may even mastermind "inside jobs" in the denigrated parent's house; for example, stealing money from the alienated parent and encouraging the destruction of property. The word sabotage is an appropriate term for such maneuvers.

A divide-and-conquer approach is usually warranted in situations in which older children are programming younger siblings to sabotage the visit, provoke the targeted parent, and cause him or her grief in other ways. This is best accomplished by requiring the children to visit separately-or at least separate from the older sibling programmer--until they all (including, possibly the alienating parent) have had the actual experience that the terrible consequences of being alone with the targeted parent were not realized. For example, an older sister may be programming her two younger brothers into believing that their father is dangerous and noxious. When they visit with the father and relax their guard, she may quickly remind her younger brothers about the indignities they are likely to suffer in his home. Structuring the visitations so that the sister visits the father separately from her brothers (at least for a time) is the most effective way of dealing with this kind of problem. We see here a good example of an important aspect of the therapy of PAS families, namely, that less is gained through the attempt to get family members to gain insight, and much more is accomplished by structuring situations and providing individuals with actual experiences.

The times when the children are transferred from the home of the alienating parent to that of the victimized parent may be especially difficult for PAS children. It is then (when both parents and the children are together) that the loyalty conflicts become most intense and the PAS symptoms most severe. In that setting--with the alienator directly observing the children--they are most likely to resist going with the victimized parent and will predictably gain the programmer's support (overt or covert) for their resistance. Alternative transitional arrangements must therefore be devised-arrangements that do not place the children in a situation in which they are with the mother and father at the same time.

A good transition place in the therapist's office. The programming parent brings the children, spends some time with them and the therapist, and then goes home, leaving the children alone with the therapist. It is important that the alienator leave the therapist's office and not wait (even in the waiting room) for the targeted parent to appear. To allow the PAS-inducing parent to remain in the vicinity will predictably sabotage this transitional arrangement and, ultimately, the whole therapeutic program. The therapist then spends time with the children alone. Subsequently the deprecated parent arrives, spend time with the children and the therapist, and then takes them to his or her home. Another option for transfer is to use a truly impartial intermediary, with whom the children have a good relationship, who picks the children up at the alienator's home and brings them to the targeted parent's home. A guardian ad litem, or a neutral third party (which can be hard to find), can serve in this role.

In some families, the children do best with a gradual expansion of the relatively restricted visitation that the court may have previously ordered for the reviled parent. In many cases, the court recognizes the limitations of the earlier stringent visitation program and has made its wishes known to all parties that an expansion is desired. Ideally, the therapist should have the freedom to make the decisions regarding just how much expansion should take place and at what rate. It is impractical (and obviously very expensive and time consuming) to go back to court every time a modification of a visitation schedule is to be effected. With rare exception, in the course of such expansion PAS-inducing parents will complain that the therapist is going too rapidly and not giving the children enough time to adjust. When empirically monitoring such visitations, therapists must rely on their own observations of the children after visitations and recognize that the reports being given by the parties about exactly what happened during the course of the visits may not be fully accurate. It is a serious error for the therapist to allow him- or herself to be controlled by PAS inducers into slowing down and even preventing a reasonable expansion of visitation. One PAS-inducing mother viewed these empirical expansions as "experiments" on her children and stated that "I won't subject my child to experiments. They're not guinea pigs." In a proper court-ordered therapeutic program, such a mother would have no choice but to allow her child to be "experimented" with.

The therapist does well to view one aspect of the children's treatment as a kind of "debriefing" and "deprogramming." The principles used are similar to those implemented with prisoners of war who were inculcated with enemy propaganda and were brainwashed into professing public hatred of the country for which they were originally fighting. An example of this is the brainwashing of American prisoners of war by their North Korean captors during the Korean War. It also is similar to the kind of programming used with youngsters who were forcibly indoctrinated into religious cults that have lured children away from their families. An example of this would be youngsters who were indoctrinated into the "Moonies" cult in the 1970s. The same programming was attempted more recently for those held hostage in Iran. One must try to help PAS children appreciate that they have been brainwashed. Obviously, older children are more likely to appreciate this than younger ones. Sometimes a focus on absurd and ludicrous allegations may help the PAS child gain such insights. It also is useful to say things along these lines:

I'm not asking you to take my word for it. I want you to use your own observations. I want you to think about what happened during your last visit with your father and ask yourself whether or not the things your mother said would happen actually happened. During your next visit, I want you to keep your eyes open and come to your own conclusions regarding whether or not these dangers and practices actually exist. You say you're old enough and smart enough to come to your own conclusions. Okay, smart people come to conclusions on the basis of their own observations, not on the statements made by others-whoever they may be. lust as I asked you before to give me proof of what you believe on the basis of what you've seen in the past, I want you to give me proof next time, after your next visit, on the basis of what you yourself have actually seen and experienced.

I have come across a few situations in which the children and the family were split regarding the success of the programmer's attempts at alienation. Specifically, one or more of the children were successfully programmed, and one or more were not. I also have seen cases in which a mother was successful in programming one or more children, and the father was successful in programming one or more children. The civil war resulted in two divided camps. One maneuver (I am hesitant to call it therapeutic) the therapist might use in these situations is to formulate a "trade-off": The children in Home A will visit Home B only if the children in Home B visit Home A. Or, more specifically, if the mother wants to see the children who live in the father's home, then she must allow the children in her home to visit with the father. Such a requirement may be dictated by the court-ordered therapist and even by the court. The court order can also give the children "excuses" for visitation. I sometimes refer to this as a "trade-of-prisoners" program.

The obvious drawback of such an arrangement is that the children are truly being used as pawns in a chess game, and this cannot but be psychologically detrimental. My limited experience with such a situation has led me to the conclusion that its advantages outweigh its disadvantages. As is true with most divorce conflicts, there is no such thing as one "good" solution, one "bad" solution. Rather, we have to decide which we consider to be the least detrimental of all the detrimental options available. I consider the swapping arrangement less detrimental than no visitation at all. As mentioned, a psychological bond, no matter how strong, can tolerate only a certain degree of attenuation, beyond which it becomes destroyed completely.

When working individually with PAS children, the therapist must discourage them from "buttering up" each parent and saying to each what they think that parent wants to hear at the moment. In family sessions the therapist should "smoke out" the lies. This is much more likely to be accomplished in family sessions than in individual meetings. Therapists should express incredulity over the children's vilification of the targeted parent. They should not take seriously the children's allegations, quickly refute and discount allegations that are patently false, and should then move on to other subjects. However after visits with the alienated parent, therapists should emphasize to the children that their view of that parent as an ogre was not realized during the visitation. The therapist does well to appreciate that as long as the litigation goes on, direct work with the children will be difficult and complete alleviation of PAS symptoms may not be possible. Accordingly, in communications to the judge, the therapist should be ever reminding him (her) of the fact that the longer the litigation goes on, the less the likelihood the treatment will be successful.

Once the court has made a final decision that the children shall remain living with the parent with whom they have the stronger, healthier psychological bond (most often the mother), then the children are often able to dispense with their PAS scenarios of deprecation. This is especially the case in the mild types of PAS and most of the children in the moderate category. This is a very important point, The children develop their campaigns of denigration because of the desire to maintain the psychological bond with the parent with whom they have been most deeply bonded. The custody litigation has threatened a disruption of this bond. Once the court has ruled that the children shall remain living primarily with the parent with whom they are more deeply bonded, they can relax and allow themselves to enjoy a more benevolent relationship with the targeted parent. In short, the court's order obviates the need for the symptoms, and so they can often be dispensed with. It would be an error for the reader to conclude that so quick an evaporation of symptoms is uniformly the case after a court order. The shorter the duration of programming, the greater the likelihood that this will happen. In contrast, if there have been many months and even years of programming, the court order is not likely to be so quickly effective. The programming has become deeply embedded in the children's brain circuitry and is not going to evaporate so quickly. Only with time, experience, and further therapy will there be any chance for the alleviation of symptoms under these circumstances.


Parents who are the victims of PAS are often quite confused regarding what has happened to their families. The alienation may have come like "a bolt out of the blue," and they may be speculating feverishly regarding what has gone on. It is as if one day they had warm and loving children and the next day they were victims of ongoing vilification and denigration. Accordingly, after a detailed inquiry has been conducted and the diagnosis confirmed, the therapist does well to explain the process by which PAS developed. Without such an evaluation, the explanations are likely to be mere speculations. The old wisdom "knowledge is power" is applicable here. The more one understands the causes of a phenomenon, the better is one's position to deal with it.

Targeted parents must also be helped to appreciate that the opposite of love is not hate but indifference. They know quite well that prior to the onset of the campaign of denigration the children were friendly, loving. and reasonably cooperative. The children's sudden transformation of personality cannot possibly mean that all love and affection have been obliterated completely from their brain circuitry. The children's preoccupation with the targeted parent belies their underlying affection, as strange as this may seem to the alienated parent. I sometimes find the following example useful: Boy A meets a girl. After a few dates, he decides that he is no longer interested and does not call her. In the ensuing weeks she hardly enters his mind. In contrast, Boy B dates the same girl a few times and then writes her a 25-page letter indicating all the reasons why he no longer wants to see her again. He is preoccupied with his decision to part ways. The question is this: With which boy does the girl have a greater chance of a renewed relationship? Obviously, the answer is Boy B, even though his professions of dislike: revulsion, and even hatred would ostensibly indicate that he wants nothing more to do with the girl. His 25-page letter of rejection belies his deep ongoing involvement. The PAS child is like Boy B, and targeted parents have to continually be reminded of this.

Victimized parents also have to be helped to "thicken their skins." They must be helped not to take so seriously the children's vilifications. Many victimized parents recognize that the children are most difficult during the first minutes or hours following the transfer. Subsequently, PAS children in the mild and moderate categories tend to "relax their guard" and enjoy the visitation. Some alienated parents may have to tolerate an ongoing state of animosity throughout the course of the visit. Such parents should be encouraged, however, to continue with the visits and view the hostility as basically a mask for the programming parent's benefit. They have to appreciate that the children are indeed still visiting their protests notwithstanding. This indicates that they actually want to be with the allegedly despised parent. If they really and truly did not want to visit, as is seen in cases of children in the severe category of PAS, they would not. Even younger PAS children could create such scenes, battles, and commotion that the parents would ultimately give up in despair.

Some PAS children in the moderate category are relatively calm and happy during the first hour or two of the visit, then go through a stage of rage outbursts that last one or more hours, and then revert to their previous state of friendliness. These episodes of fury should be viewed as demonstrations for the benefit of the programmer and will be duly reported on the child's return. However, at the time of such reporting, the duration and intensity of the outbursts will predictably be expanded, exaggerated, and presented as responses to some terrible indignity suffered at the hands of the targeted parent. No mention at all will be made of the good times that might have comprised 95+% of the visit. Sometimes the rage outbursts represent a release of pent-up anger generated by the child's embroilment in the parental conflict.

Victimized parents must be helped to divert the children from their hostile provocations to healthier interchanges and not to dwell on whether a particular allegation is true or false. I am not suggesting that targeted parents refrain entirely from any refutations of the false allegations; rather, they should make explanatory retorts short and simple and not devote significant time to them. They should point out to the children the most egregious examples of the programmer's distortions and ask them whether they themselves have had experiences that verify these allegations. This is best done at the time when an alleged indignity or persecution is supposed to be taking place. Healthy living experiences, however, are the most effective antidotes to the PAS child's delusions regarding the targeted parent's allegedly noxious and dangerous qualities. Much more time should be spent providing the children with experiences that negate the validity of the false accusations. The victimized parent can be engaged by the therapist as a therapeutic assistant in the deprogramming process. In the course of such meetings the targeted parent provides examples of the false allegations, which then serve as points of departure for a therapeutic discussion among the parties, a discussion that focuses on the falsity of the allegation.

Targeted parents should be encouraged to talk to the children about "old times" together and to engage in the playful interchanges that may have been manifestations of the bonding that took place at that time. Healthy parents and children engage in special "private" games that are unique to each relationship. These may involve singing special songs, involvement in certain playful activities, or using special terms and phrases that are ideosyncratic to that particular parent-child relationship. Engaging the children in a repetition of these activities and interchanges can be quite salutary and play an important role in reducing PAS symptoms and in rebuilding an attenuated psychological bond.

On occasion, victimized parents will request police accompaniment when they pick up their children for visitation. Typically, they bring to the visit a court order that clearly indicates to the police that the pickup time is a valid one. Obviously, this is not done the first time a separated parent visits. It is resorted to only after numerous frustrations and rejections at pickup time. As is true for most activities, there are advantages and disadvantages to this maneuver. The main advantages are that it increases the likelihood that the children will visit and thereby reduces the targeted parent's frustrations and pent-up anger. It also has an advantage for the children in that it provides them with an excuse for the programming parent; for example, "We really hate to go with him (her), but if we don't someone may get arrested." As mentioned, I cannot emphasize strongly enough the importance of providing PAS children with excuses that they need to give the programming parent if they are to visit the alienated parent. A disadvantage of bringing along the police is that it may produce fear in the children. After all, police are often seen as awesome authorities to children, and they may be frightened that they, themselves, will be arrested. I have no strong position on this particular issue. There are situations in which the advantages outweigh the disadvantages, and there are other situations in which the opposite is the case. As is true with many other clinical decisions, an empirical trial is often the best procedure for ascertaining whether a particular procedure will be beneficial. The therapist does well to explore this issue in selected cases and, when in doubt regarding what to recommend, try it once or twice and then assess the family members, especially the children, for their various reactions.

Most important, victimized parents have to be encouraged to "hang in there" with the philosophy that relationships based on genuine love may ultimately prove stronger than relationships based on fear. Alienated parents should be helped to appreciate (if they don't know already) that the children's animosity toward them is based primarily on the fear of alienating their programmers, especially if they express any affection for the alienated parent. Victimized parents should provide the children with an atmosphere in which they permit them to express all thoughts and feelings, both positive and negative, regarding both parents. This is a different environment from the indoctrinating parent's home, wherein the children are not allowed to express any criticism at all of the programmer or any affectionate feelings for the targeted parent. In the home of the programmer the children live in a state of fear lest they break these stringent rules. The hope is that, ultimately, the children will come to appreciate this difference and recognize the greater state of relaxation and pleasure they enjoy in the victimized parent's home. Targeted parents in the moderate category of PAS have to be helped to appreciate that things could be worse, that the children are not in the severe category--in which situation they would not be visiting at all. The very fact that the children are visiting indicates that they want to be with the alienated parent, their protests to the contrary notwithstanding. If the children really did not want to be with the targeted parent, their ongoing screaming, kicking and blood-curdling shrieks would make visitation impossible, except for the very youngest children. Victimized parents in the moderate category have to be continually reminded of this important fact and persuaded to take some solace from this.


I can think of no better example of the way in which mental health and legal professionals can work together than the treatment of PAS families. When such cooperation is full and complete, the likelihood of success is reasonably good. In contrast, when such cooperation is not present, therapy is likely to prove futile and the result of such therapeutic failure is likely to be progression of the PAS down into the severe realm, with the high probability of lifelong alienation of the children from the targeted parent. MY experience has been that courts are generally reluctant to impose the more stringent sanctions suggested here, with tragic results for the family. My experience also has been that there are few therapists who are willing to or capable of implementing the more stringent treatment program recommended here. The "Mr. (Mrs.)-good-guy"' approach, so important in traditional individual and family therapy, has no place in the treatment of PAS families. Only therapists who are comfortable with stringent and authoritarian treatment procedures should be involved in conducting therapy with PAS families. Therapists who are capable of making this switch can provide these families with significant help if they are able to gain court support for their treatment. Unfortunately, my experience has been that such support from the court is rarely forthcoming. One of my purposes in writing this article is to bring attention to this problem, in the hope that both mental health and legal professionals will modify their attitudes and thereby provide these families with sorely needed assistance, which they are not yet receiving in the vast majority of cases.


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

Gardner, R. A. (1986). Child custody litigation: A guide for parents and mental health professionals. Cresskill, NJ: Creative Therapeutics.

Gardner, R. A. (1987a). The parental alienation syndrome and the differentiation between false and genuine child sex abuse. Cresskill, NJ: Creative Therapeutics.

Gardner, R. A. (1987b). Child custody. In J. D. Noshpitz (Ed.), Basic handbook of child psychiatry (Vol. 5, pp. 637-646). New York: Basic Books.

Gardner, R. A. (1989). Family evaluation in child custody mediation, arbitration, and litigation. Cresskill, NJ: Creative Therapeutic.

Gardner, R. A. (1991). Sex abuse hysteria: Salem witch trials revisited. Cresskill, NJ: Creative Therapeutics.

Gardner, R. A. (1992a). The parental alienation syndrome: A guide for mental health and legal professionals. Cresskill, NJ: Creative Therapeutics.

Gardner, R. A. (1992b). True and false accusations of child sex abuse. Cresskill, NJ: Creative Therapeutics.

Gardner, R. A. (1993a). The child abuse prevention and treatment act for dealing with sex abuse hysteria in the United States. Issues in Child Abuse Accusations, 5(1), 25-27.

Gardner, R. A. (1993b, February 22). Modern witch hunt-child abuse charges [Op-Ed article]. The Wall Street Journal.

Gardner, R. A. (1993c). Sex-abuse hysteria: Diagnosis, etiology, pathogenesis, and treatment. Academy Forum, 37,(3), 2-5.

Gardner, R. A. (1995). Protocols for the Sex-Abuse Evaluation. Cresskill, NJ: Creative Therapeutics.

Gardner, R. A. (1996). Psychotherapy with sex-abuse victims: True, false, and hysterical. Cresskill, NJ: Creative Therapeutics.

Gardner, R. A. (in press). The Burgess decision and the Wallerstein brief. Journal of Psychiatry and the Law, 26(3), 1-7.

Gardner, R. A. (1998). The parental alienation syndrome (2nd ed.). Cresskill, NJ: Creative Therapeutics.

Rand, D. C. (1997a). The spectrum of parental alienation syndrome (Part I). American Journal of Forensic Psychology, 15,(3), 23-52

Rand, D. C. (1997b). The spectrum of parental alienation syndrome (Part II). American Journal of Forensic Psychology, 15(4), 39-92

Waldron, K. H., & Joanis, J. D. (1996). Understanding and collaboratively treating parental alienation syndrome. American Journal of Family Law. 10, 121-133.

Address correspondence to Richard A. Gardner, M.D.,
155 County Road, Cresskill, NJ 07626-0522 US

Guidelines for Assessing Parental Preference in Child-Custody Disputes

Journal of Divorce & Remarriage, 1999, 30(1/2):1-9


Since the early 1960s I have been developing guidelines for legal and mental health professionals to utilize when conducting an assessment in the context of child-custody disputes (Gardner, 1982, 1986, 1989, 1992, and 1998). Over the years, I have seen attempts to quantify such evaluations with scales and score sheets. This approach is particularly attractive to those who hold that such instruments add a certain degree of "objectivity" to such assessments, objectivity that is not apparent when one uses evaluative formats in which there are no scores or formal quantification. I believe that guidelines that provide the evaluator with specific relevant areas to focus on can be useful. In the state of Michigan, a set of such guidelines is not only widely used but courts are required to follow them when making decisions in child-custody cases. The Michigan guidelines (1993) require the evaluator to compare the parents on 12 factors that are considered to be applicable to a custody/visitation determination regarding what is in the best interests of the child. Although I consider there to be some weaknesses and omissions in the Michigan criteria, I believe the principle is a sound one. Especially attractive to me is the requirement that the parents be compared on each of the items, following which the examiner comments on which parent has been preferred on each of the items and then tallies the total score for each parent.

In this report, I utilize the same principle but provide what I consider to be a superior set of guidelines, guidelines that expand upon what I consider to be the valid criteria in the Michigan protocol and omit (in part or in toto) what I consider to be the weaker criteria. Elsewhere (1999), I have published on these guidelines.

1) The Stronger, Healthier Psychological Bond.

This is first criterion because I consider it the most important. The best-interests-of-the-child presumption is too vague to be particularly useful. Everyone waves that flag: both parents, both lawyers, the judge, the guardian-ad-litem, and the parade of mental health professionals who testify on both sides. No one claims not to subscribe to this principle. No one claims that he (she) is operating against the best interests of the child. What usually happens is that all these vociferous proponents of this principle cancel each other out. Accordingly, the best-interests-of-the-child guideline is meaningless. Actually, what we are really trying to assess in a child-custody dispute is which parent has the stronger and healthier psychological bond with the child. Many aspects of the evaluation provide data of use in making this specific assessment. Joint interviews can be particular useful here, e.g., father plus child, mother plus child, both parents plus child. Particularly useful are interviews in which both parents are seen together in which they have the opportunity to confront one another directly with their often conflicting opinions regarding a whole series of events.

When implementing this particular criterion, I utilize the following principles:

a) Preference should be given to that parent (regardless of gender) with whom the child has developed the stronger, healthier psychological bond.

b) That parent (regardless of gender) who was the primary caretaker during the earliest years of the child’s life is more likely to have developed the stronger, healthier psychological bond.

c) The longer the time gap between the earliest years of the child’s life and the time of the custody evaluation or decision, the greater the likelihood other factors will operate that may tip the balance in either direction regarding parental capacity.

It is important to note that this criterion is only applicable when the bonding being assessed is healthy. Obviously, pathological bonds can exist between a parent and child, but their presence would not argue for primary parental designation. Rather, their presence would often argue against such designation.

2) Parenting Capacity

This criterion focuses on the comparative ability of the parents to properly and effectively raise the children. It includes knowledge of child-rearing techniques and the utilization of humane and reasonable disciplinary measures. It includes the knowledge of how to provide the children with guidance, instruction, and care.

3) Values and Morality

Parents serve as models for their children. Accordingly, a parent with unhealthy values and/or immoral behavior is likely to transmit these undesirable qualities to the children. The evaluator assesses here honesty, sensitivity to the feelings of others, social commitment, lifestyle, and other personality qualities which would be useful for the child to emulate and identify with.

4) Availability

The evaluator should give consideration to the availability of each of the parents who are involved in the child’s life. Particularly important is each individual’s availability for getting the child off to school, being available on their return, and being available to care for the child during illnesses and emergency situations. This criterion also refers to availability to care for the child during school holidays and during the evening for homework assistance.

5) Educational Commitment (Curricular and Extracurricular)

The evaluator should compare the parents with regard to their genuine commitment to the educational process and the appreciation of its importance in the child’s life. Such commitment not only manifests itself by what the parent says but, more importantly, by what the parent does with regard to his (her) actual involvement in the child’s school activities. This includes parent-teacher conferences, PTA meetings, as well as attendance at school extracurricular activities, e.g. sports, music and dance recitals, plays, etc. The evaluator does well to try to determine the degree of pride and joy each parent has when observing the child’s involvement in the extracurricular activities.

6) Health Care (Physical and Mental)

The evaluator should compare each parent’s commitment to and availability for involvement in the child’s health care. This includes visits to health care providers, both physical and mental, e.g., pediatricians, psychologists, and psychiatrists. It also involves availability and commitment to the child when physically ill and home care is required.

7) Appreciation of the Role of the Other Parent in the Child’s Upbringing

The evaluator should compare each parent’s appreciation of the importance of the other parent in the child’s upbringing. Parents who try to exclude the other parent from the child’s life exhibit a parental impairment. This is especially the case if such exclusions are associated with attempts to denigrate the other parent to the point that the child may develop complete alienation from the targeted parent (Gardner, 1992, 1998).

8) Cooperation

The evaluator should compare the parents regarding the willingness to cooperate with the other parent concerning issues relevant to the healthy growth and development of the child. Although divorce hostilities may interfere with such cooperation, healthy and committed parents recognize that it is important to separate their own interpersonal difficulties from the important obligation that both of them have to cooperate in the raising of the child. Although angry and irritated with one another regarding unresolved divorce issues, healthy and committed parents are still able to cooperate with one another regarding the care of the child. Parents who require court orders before cooperating with the other parent on issues related to the child’s healthy growth and development are exhibiting a parenting impairment.

9) Communication

The evaluator should compare the parents with regard to their receptivity to communicating openly and freely with one another on issues relevant to the growth and development of the child. Parents who refuse to speak on the phone with one another exhibit a parenting deficiency and this is especially the case for parents who insist on communicating only through lawyers.

10) Commitment to Providing the Child with Food, Clothing, and Shelter

The evaluator should compare the parents with regard to their commitment to providing the child with the basic necessities of life: food, clothing, and shelter. This criterion has less to do with the actual amount of money the parent earns and more to do with the sense of commitment to providing the children with these necessities of life.

11) Physical Health of Each Parent

Obviously, in order to care properly for the child, the parent must be reasonably healthy physically. Accordingly, the examiner should get information in this realm in the course of conducting the evaluation.

12) Psychological Health of Each Parent

Each parent should be assessed psychologically to ascertain the presence of significant psychological disorders. It is not necessary that formal psychological tests be administered to each parent in the context of a child-custody evaluation. Generally, clinical information obtained from each parent about himself (herself) and about the other party will provide the necessary data. One is particularly interested in obtaining information about severe forms of psychopathology, especially when hospitalization has been required. Accordingly, the examiner should assess for evidences of psychosis, severe personality disorder, substance abuse, abuse of family members (emotional, physical, or sexual), psychopathy, and difficulties with law-enforcement officials. Relatively mild forms of psychopathology should not generally be given significant consideration here because both parents are likely to have some diagnosis and it is not generally useful to compare whether mild psychopathology category A makes one less capable as a parent than having a mild form of psychopathology B.

13) Presence of Parental Surrogates in Each Parent’s Home

The evaluator should determine whether parental surrogates are living in or immediately available to the homes in which the child lives. These would include stepparents, new partners or companions, grandparents, and other individuals who are significantly involved in the child’s life and would be reasonably available—on a continuing basis—to be involved in the child’s care. Although housekeepers and maids may be given consideration in the assessment of this criterion, the evaluator should appreciate that many such individuals may be transient in the child’s life.

14) Appreciation of the Dangers of the Child’s Exposure to and Embroilment in the Parental Conflict

Healthy parents recognize that it is important not to expose the child to or embroil the child in the parental conflict. In contrast, parents who utilize the child in their conflict, e.g., as a weapon, as a rope in a tug of war, as a spy, and as a saboteur, are exhibiting a parental deficiency. Parents who induce in the child a campaign of denigration against the other parent, utilizing the child then as a weapon in the parental conflict also represent a significant parenting deficiency.

15) Commitment to the Child’s Enrichment

This indicator focuses on commitment to the child’s involvement in activities beyond those provided in the school (both curricular and extracurricular). This would include a wide variety of enrichment activities including music lessons, sports, scouting, camping, gymnastics, travel, visits to museums and historical sites, and other forms of intellectual and emotional stimulation.

16) Extended Family Involvement

Healthy parents recognize that it is important for the child to have a sense of family ties, an appreciation of one’s importance in the family network. This not only includes the extended family of the parent himself (herself) but also the extended family of the estranged spouse. Parents who expand their acrimony from the spouse to the spouse’s extended family manifest a parenting deficiency.

17) Involvement with the Child’s Friends

Healthy parents recognize the important of friends in a child’s life. Accordingly, they facilitate visits by friends to the home and the child’s visiting friends in other homes. They also facilitate overnight visits as well. Accordingly, the evalutor should compare the parents with regard to their receptivity to the child’s involvement with peers.

18) Pride in the Child

Healthy parents have pride in their children. This is one manifestation of their love. Such a parent’s heart swells with pride when observing the child in school recitals, plays, and sporting events. Healthy parents may cry with joy on such occasions. They carry pictures in their wallets of their children and are quick to display these with pride to anyone who shows interest in looking at them. A reasonable degree of boasting about the child is also healthy and a manifestation of good parenting. Of course, when boasting is excessive or pride is being used in the service of denial of a child’s obvious weaknesses, then this criterion is not satisfied.

19) The Child’s Own Stated Preference

It is not by pure chance that this criterion is put near the bottom. Obviously, for younger children it is not a consideration. But even for older children it may be a risky indicator because the child’s cognitive immaturity may result in his (her) stating preferences that are not really judicious, e.g., a six-year-old states, "I want to live with my daddy not my mommy. My daddy is a lot of fun. He buys me pizza and we play ball a lot. He lets me stay up and watch television. My mommy’s mean. She makes me go to sleep early and makes me do homework." Furthermore, children who have been subjected to a program of alienation (Gardner, 1992, 1998) may profess preferences as a manifestation of their being programmed to denigrate a parent who might very well serve as a good and effective primary parent.

20) Commitment to the Care of the Handicapped Child

Raising a handicapped child is one of the most sensitive tests of parenting capacity. A parent with compromised commitment is likely to exhibit such compromises when called upon to take on the extra tasks and burdens of rearing such a child. Obviously, then, preference should be given to the parent who exhibits greater commitment in such situations.


The examiner who focuses on these 20 areas, not superficially but in depth, is likely to be able to make reasonable parental preference recommendations in the vast majority of child-custody evaluations. In most cases the examiner will find that the parent for whom the evaluator recommends primary custody is likely to be superior in the majority of these indicators. It is important to note that I have studiously avoided giving any specific number of criteria that must be satisfied or any specific cutoff point. Rather, the examiner should operate on the principle that the greater the number of items on which a particular parent is superior the greater the justification for recommending that parent to be designated the primary custodial parent.


Gardner, R.A. (1982), Family Evaluation in Child Custody Litigation. Cresskill, New Jersey: Creative Therapeutics, Inc.

_______ (1986), Child Custody Litigation: A Guide for Parents and Mental Health Professionals. Cresskill, New Jersey: Creative Therapeutics, Inc.

_______ (1989), Family Evaluation in Child Custody Mediation, Arbitration, and Litigation. Cresskill, New Jersey: Creative Therapeutics, Inc.

_______ (1992), The Parental Alienation Syndrome. Cresskill, New Jersey: Creative Therapeutics, Inc.

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

_______ (1999), Guidelines for assessing parental preference in child-custody disputes. Journal of Divorce & Remarriage, 30(1/2):1-9.

Michigan Guidelines for Assessing Parental Preference. MCL 722.23; MSA 25.312(3), as amended by PA 1993, No. 259, 1. effective November 1993.

Intervention-guided single case-help and parental alienation syndrome by Werner G.pdf

Parental Alienation Joel R.pdf

Parental Alienation Syndrome - How to Detect It and What to Do About It by J. Michael Bone and Michael R.pdf

Parental Alienation Syndrome PAS_ Sixteen Years Later.pdf

Parental Alienation Syndrome vs. Parental Alienation: Which Diagnosis Should Evaluators Use in Child-Custody Disputes?

Should Courts Order PAS Children to Visit/Reside with the Alienated Parent.pdf















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