Evidence submitted by Dr L F Lowenstein, Educational, Clinical and Forensic Psychological Consultant

I have been for some considerable time acting as an Expert Witness for parents who have had in many cases many years of no contact with their natural children.

The Courts and Judges most particularly have been lacking in the capacity to understand how best to deal with this problem. Mr Tony Coe, Chairman of the Equal Parenting Council and Mr David Levy of the Children’s Rights Council have put forward documents, with which I totally agree,concerning the current injustice, mostly towards fathers, in their having contact with their offspring.

I have written a large number of articles on the subject of parental alienation, sometimes termed Parental Alienation Syndrome (PAS). These article have been published in many cases in legal journals and I am submitting a list of these articles for your consideration.

You are undoubtedly wish information concerning the matter of parental alienation in order to deal with it in a just, fair and reasonable manner.

My own experience in the Courts has been that Judges often fail to take heed of expert witnesses accounts/opinions if they present a strong and decisive case that one of the parents, usually the father, has a right to contact with their natural child, and the amount of time that should be provided.

The custodial parent is often resistant to the other parent having contact and will do virtually any thing to prevent it.

Judges in my experience have failed to take strong and determined action against the custodial parent which would be to the benefit of children as well as to the ostracised and non-custodial parent. It is time this matter was resolved.

The evidence put forward by Mr Tony Coe, Chairman of the Equal Parenting Council, of what is being done in the United States puts the UK to shame in relation to providing equal justice for non-custodial parents, mostly fathers.

It is for this reason that there have been developing somewhat ‘radical bands of individuals’ who have in some cases gone beyond the law to draw attention to the plight of frustrated and neglected fathers.

My treatment from the judiciary in court has been varied. Probably the worst treatment that I have personally experienced with the Judiciary as an expert witness in seeking to resolve the problem of access of parents to their children was with a particular Judge in South Wales.

His attitude was dismissive and pretty dismal in that he even failed to provide me with the courtesy of meeting me, despite having travelled to the Court in Swansea from my home in Hampshire, following my having written a long report in which I have attempted to help make a decision in
relation to a father who had not been allowed to see his child and whose wife had taken the liberty of moving away with their mutual child.

I have seldom met such discourteousness or the lack of opportunity of at least being heard
and putting my points of view forward.

A book is currently in the process of being published in the United States on Parental Alienation in which have a chapter on the damage that is done to children by their failing to have contact with one of their parents, and the longterm effects this has on the child. Needless to say, the damage caused to the non-custodial parent is equally powerful.

I do hope your committee will do as much as possible to resolve this matter and I hope that you will have the opportunity of obtaining the articles that I have delineated following this letter. Should you have difficulty in obtaining them please do make contact with me.
Dr L F Lowenstein
Educational, Clinical and Forensic Psychological Consultant

PA around the world

ARGENTINA In 1993, the legislature of Argentina adopted a law (Ley 24270) that provides criminal penalties for “a parent or a third person who illegally prevents or obstructs contact of a minor with his or her nonresidential parent.” This law has been used to prosecute parents who alienate their children against the other parent. A book by Graciela N. Manonelles, Responsabilidad penal del padre obstaculizador, La. Ley 24270. Sindrome de alienacion parental (SAP) (Crim- ´ inal Responsibility of the Obstructing Parent, Law 24270. Parental Alienation Syndrome [PAS]), explains the concept of PAS and also discusses legal cases and prosecution of alienators (Manonelles, 2005). In 2008, two Argentines, Delia Susana Pedrosa and Jose Bouza, pub- ´ lished an important book, S´ındrome de Alienacion Parental. Proceso de ob- ´ struccion del v ´ ´ınculo entre los hijos y uno de sus progenitors (Parental Alienation Syndrome: The Process of Obstructing the Bond between the Child and Parent) (Pedrosa and Bouza, 2008). It is notable that this book received a favorable review in the publication of the National Academy of Sciences of Buenos Aires.

AUSTRALIA Sandra S. Berns, Ph.D., a professor at Griffith Law School, Brisbane, has written extensively on family law. She conducted research regarding divorce judgments in Brisbane, Australia, and found that parental alienation syndrome was present in 29% of cases (Berns, 2001). In commenting on the role of PAS in family courts in Australia, Berns said, “Although the Australian Family Court will admit evidence of PAS in appropriate cases … and has given that evidence weight in decision making, the intense politicization of PAS remains a significant problem for the court. Injudicious statements both by those advocating full legal recognition of PAS and by those opposing such recognition have created a climate in which the courts and the legal profession are skeptical and reluctant to move too far in advance of settled legal and psychiatric opinion” (Berns, 2006).

BELGIUM Several mental health professionals in Belgium have observed and written about PAS. A Belgian journal for mental health professionals, Divorce & Separation ´ , devoted its June 2005 issue to the topic of parental alienation. For instance, that issue of the journal included an article by Didier Erwoine, M.A., a Belgian clinical psychologist, “Les traitements du Syndrome d’Alienation ´ Parentale” (“Treatments of the Parental Alienation Syndrome”). Erwoine said that one of the most dramatic elements of PAS was its often “incurable and irreversible” aspect. In Erwoine’s opinion, it is absolutely essential to combine psychotherapeutic treatment with court ordered measures in order to reverse the PAS inducing process (Erwoine, 2005). Benoit van Dieren, Ph.D., a psychologist, family therapist, family mediator, and expert, identified PAS in some of the families he assessed in Brussels. He has started to educate mental health and legal professionals regarding this topic. Van Dieren reported, “I have always perceived this ‘disorder’ as a systemic problem, that is, a problem that can be understood only if we consider the complex and dynamic relationships between at least three poles: the child, the father, and the mother, plus the other elements gravitating around these poles such as the extended families, friends, new partners, and the judicial and psychosocial systems.” In Belgium, van Dieren has helped to organize a multidisciplinary group (a magistrate, a lawyer, a mediator, and a psychologist) to study how to detect PAS and how to intervene when it occurs. They have promoted an approach that is combined (both judicial and psychological functions), coordinated, and rapid. Jean Yves Hayez, M.D., Ph.D., a child psychiatrist at the Catholic University of Louvain, wrote a cautionary article, “L’Alienation Parentale, un concept a haut risque” (“Parental Alienation: A high risk concept”) (Hayez ` and Kinoo, 2005). Hayez thought the concept of parental alienation should Downloaded By: [VUL Vanderbilt University] At: 03:50 13 March 2010 108 W. Bernet et al. be limited to cases in which the toxicity of the guardian parent is evident, for example, in psychotic or highly disturbed parents. Finally, in 2008, Jean-Emile Vanderheyden, M.D., a neuropsychiatrist, edited and published an important book, Approcher le divorce conflictuel (Approaching Conflicting Divorces). This is a multidisciplinary book that discusses high-conflict divorce from a number of perspectives. The chapter authors include judges, lawyers, family mediators, social workers, neuropsychiatrists, and psychologists. The book includes poignant statements by mothers and fathers who experienced loss of their children through parental alienation. There are discussions of the misdiagnosis of parental alienation and the mismanagement of it by the justice system. The authors make various suggestions ranging from the training of competent judges to the designation of “a special day in the calendar” in order to improve societal awareness of parental alienation.

BRAZIL Maria Berenice Dias is a distinguished appellate judge who has been a leader in the Brazilian women’s movement, particularly fighting against domestic violence. Judge Dias has been active—both in Brazil and internationally—in teaching and writing about family law. Her website ( includes a notable article, “S´ındrome da alienac¸ao parental, o que ˜ e isso?” (“Parental alienation syndrome, what is ´ it?”) (Portuguese). Judge Dias said, “Certainly everyone involved in the study of family conflict and violence in interpersonal relationships has come across a phenomenon that is not new, but that has been identified by more than one name. Some call it ‘parental alienation syndrome,’ others refer to it as ‘implantation of false memories.’” After citing the work of “the American psychiatrist, Richard Gardner,” Judge Dias said, “The child, who loves his parent, is taken away from a father who also loves him. This generates a conflict of feelings and a destruction of the bond between them. … In this game of manipulation, all weapons are used, including the assertion of the child having been the victim of sexual abuse. …The child cannot always discern that he is being manipulated and ends up believing what he was told in such an insistent and repeated manner. Over time, even the mother cannot distinguish the difference between truth and falsehood. Her truth becomes the truth for the son, who lives with false characters of a false existence, resulting then in false memories being implanted in his mind” (Dias, 2006). Priscilla Maria Pereira Correa da Fonseca, Ph.D., a law professor, pub- ˆ lished an article in a pediatric journal, “S´ındrome de alienac¸ao parentale” ˜ (“Parental alienation syndrome”). She discussed the causes of PAS and how to identify it. Correa da Fonseca (2006) concluded, “To identify the parental ˆ alienation and prevent this harmful process from affecting the child and converting into a syndrome are tasks for the Justice. The family law lawyer must prioritize the child and adolescent even when the alienating parents demand their rights, including the refusal to support the cause of the alienating parent.” Igor Nazarovicz Xaxa wrote a dissertation at Universidade Paulista, ´ Bras´ılia, which was titled, A S´ındrome de Alienac¸ao Parentale eo Poder Ju- ˜ diciario (The Parental Alienation Syndrome and the Judiciary). Xax ´ a, who ´ apparently was himself an alienated or targeted parent, described how resistant Brazilian officials were to appreciating the serious consequences of PAS (Xaxa, 2008). There is now a movement in the National Congress of Brazil ´ to adopt measures (Bill Number 4053) that address parental alienation and seek to protect children and adolescents from this type of abuse.

CANADA Mental health and legal professionals in Canada have been familiar with the concept of parental alienation for many years. Perhaps the earliest discussion of PAS in the professional literature in Canada was a 1991 article by Anne-France Goldwater in a law journal, “Le syndrome d’alienation ´ parentale” (Goldwater, 1991). In 1992, Abe Worenklein, Ph.D., a clinical and forensic psychologist, published “Custody Litigation and Parental Alienation” (Worenklein, 1992). More recently, Gold-Greenberg and Worenklein (2001) published “L’alienation Parentale, un D ´ efi L ´ egal et Clinique pour les ´ Psychologues” (“Parental Alienation, a Legal and Clinical Challenge for Psychologists”). Hubert Van Gijseghem, Ph.D., a professor at the University Montreal, has conducted research and written extensively regarding parental alienation (Van Gijseghem, 2002, 2004, 2005b, 2009). For instance, he reported his attempts to calculate the prevalence of parental alienation in metropolitan Montreal in an interesting article, “L’Alienation parentale: Points con- ´ troverses” (“Parental alienation: Controversial points”). In this article, Van ´ Gijseghem acknowledged that the concept of parental alienation is not accepted by everybody, and he commented on the emotional debates regarding this topic. He concluded, “That the phenomenon does exist, there is no doubt, but we will have to wait another decade to resolve several aspects of the controversy” (Van Gijseghem, 2005a). Van Gijseghem has also organized training workshops regarding parental alienation for professionals in Canada and European countries. Marie Hel´ ene Gagn ` e, Ph.D., and Sylvie Drapeau, Ph.D., psychologists ´ at Laval University, Quebec, published “L’alienation parentale est-elle une ´ forme de maltraitance psychologique?” (“Is parental alienation a form of psychological abuse?”). The authors proposed to use the conceptual and theoretical frame of psychological abuse to study parental alienation. They defined both concepts and described the conceptual links between them (Gagne and Drapeau, 2005)

In 2008, Barbara Jo Fidler, Ph.D., Nicholas Bala, Rachel Birnbaum, Ph.D., and Katherine Kavassalis published Challenging Issues in Child Custody Assessments: a Guide for Legal and Mental Health Professionals. Fidler and Birnbaum are mental health professionals; Bala and Kavassalis are lawyers. In the chapter titled “Understanding Child Alienation and Its Impact on Families,” the authors said, “Children from separated and divorced families who vigorously resist or refuse contact with one parent frequently are referred for child custody assessments. … There is significant debate in the mental health and legal literature about the conceptualization and etiology of parent-child contact problems, and about the most appropriate mental health interventions and judicial remedies relating to them. Although most authors agree that the phenomenon exists, finding an appropriate name for the problem is also a subject of debate” (Fidler et al., 2008a, p. 203). The Canadian Symposium for Parental Alienation Syndrome (CS-PAS) is an international, educational conference for mental health professionals, family law attorneys and other professionals dedicated to the prevention and treatment of parental alienation and PAS. The CS-PAS conferences occurred in March 2009 and October 2009 in Toronto. Additional information is available at

CZECH REPUBLIC Eduard Bakala´ˇr, C.Sc., is a psychologist who began assessing custody disputes for the Municipal Court in Prague in 1967. He has noted the occurrence of parental alienation in the Czech Republic, where mental health professionals have published articles regarding this topic. Bakala´ˇr also reported that the phenomenon of parental alienation has been described in the Ukraine and Russia, but the mental health professionals have no name for it because they are not familiar with the literature and research published elsewhere. Bakala´ˇr wrote extensively regarding parental alienation, including “Popouzen´ı d´ıtete proti druh ˇ emu rodi ´ ci” (“Inciting the child against the other ˇ parent” (Bakala´ˇr and Novak, 1996) and “Syndrom zavr ´ zen ˇ ´ı rodice: P ˇ ˇr´ıciny, ˇ diagnoza, terapie” (“Parental alienation syndrome: Etiology, diagnostics, ther- ´ apy) (Bakala´ˇr, 2006b). In his book, Pruvodce otcovstv ˚ ´ım (A Guide through Fatherhood), Bakala´ˇr included a chapter regarding parental alienation syndrome in the Czech Republic (Bakala´ˇr, 2002). In another book chapter, Bakala´ˇr discussed the psychodynamics of PAS. He said, “Competition and narcissism may play a part in the rivalry between some parents who consciously or unconsciously wish that their children will look like, act like, and think like they do. … Neurotic egotistical projection on the part of at least one parent can cause the child to favor a point of view and take sides when the child observes parental conflict and separation of the household” (Bakala´ˇr, 2006a, p. 302).

DENMARK A Danish judge who has written extensively about family law, Svend Danielsen, recently published Forældres Pligter–Borns Rettigheder (Parents’ ¨ Duties—Children’s Rights). This judge was commissioned by Nordisk Ministerrrad (the Nordic Council of Ministers) to compare family law in English- ˚ speaking countries (England, Scotland, Australia, and Canada) with the Nordic countries (Denmark, Finland, Iceland, Norway, and Sweden) to look for possible ideas for Nordic reforms. In this book, PAS was mentioned and the phenomenon of parental alienation was discussed: “It can be that the residential parent has such strong rejections against visiting rights for the other parent that the child is affected. In English justice it is called ‘implacable hostility.’ Another concept and manifestation of conflict is ‘parental alienation syndrome.’ … Generally it is unlucky to capitulate because of ill-disposed parents, resulting in no visitation. … If one of the parents makes the contact difficult or impossible, a decision on residence for the child can be altered, but this has to be the last way out, and the possibility cannot be used for solving a relatively mild contact problem” (Danielsen, 2004, pp. 210–211). The Danish organization, Foreningen Far til Støtte for Børn og Forældre (Fathers in Support of Children and Parents) was established in 1977. This organization convened a conference on parental alienation in 2002, and lectures regarding parental alienation and PAS were presented by Erik Kofod and Lena Hellblom Sjogren, Ph.D., a Swedish psychologist. The proceed- ¨ ings of this conference were published in the organization’s yearbook, “On Visitation and Parents’ Responsibility,” in September 2002.

FINLAND Anja Hannuniemi, LL.Lic.—a lawyer, licentiate of law, and medical law researcher—has conducted research and taught criminal law and medical law at the University of Helsinki for twenty years. She is preparing a doctor’s thesis about PAS. Hannuniemi has acted as an attorney, expert witness, and a judge in very difficult cases involving children. When she heard about PAS in 2000, Hannuniemi immediately realized that PAS had been a factor in all of the longest and most difficult custody disputes and compulsory guardianship cases that she had been working on as an attorney. (“Compulsory guardianship” means that the municipality becomes the custodian of the child instead of the parents.) Hannuniemi thought that in many of these cases, PAS was induced or made much worse by social workers involved with the divorced families. Hannuniemi has worked hard to educate the judiciary in Finland regarding PAS. For instance, in a lengthy article published in a Finnish legal journal, she noted, “Alienation syndrome does not result only from the close parent intentionally, semi-intentionally, or subconsciously acting to alienate the child from the other parent, but its clinical picture also includes the part of the child, in which he/she—following his/her sense of loyalty to the close parent—is susceptible to the indoctrination practiced by that parent, and actively alienates oneself from the distant parent” (Hannuniemi, 2007)

FRANCE There is considerable interest in PAS among both mental health professionals and child advocates in France. An advocacy organization, Association Contre L’alienation Parentale (ACALPA) (The Association against Parental ´ Alienation) was founded in 2004. This organization engages in extensive education of parents, legal professionals, and mental health professionals regarding PAS. ACALPA also organizes national programs for training police and gendarmerie officers regarding PAS. French psychiatrists have studied PAS and published papers regarding this topic. Paul Bensussan, M.D., for example, a psychiatric expert for the French courts, has specialized in cases of parental alienation and false allegations of child sexual abuse. In 15 years, he has studied more than 800 cases of high conflict divorce. In a recent article in a medical journal, “L’alienation ´ parentale: vers la fin du deni?” (“Parental alienation: Toward the end of the ´ denial?”), Bensussan commented that PAS “arouses polemics and controversies.” He said in the abstract, “Some go as far as denying the very existence of the phenomenon itself, arguing that it is still absent from the international classifications of psychiatric disorders (European or American). … The author describes the difficulties encountered, by judges as well as by experts, to evaluate the quality of the relationship before the split and to suggest adequate solutions, in as much as the field of action is severely restricted with such determined children or teenagers” (Bensussan, 2009). Another psychiatric expert, Jean-Marc Delfieu, M.D., published in a legal journal “Syndrome d’alienation parentale—Diagnostic et prise en charge ´ medico-juridique” (“Parental alienation syndrome—Diagnosis and medical- ´ legal management”). In this article, Delfieu described the recent increase of cases with severe mental manipulation of children, which he saw in divorce cases. He described the psychopathology, psychodynamics, and clinical manifestation of PAS, with case examples. He proposed joint therapeutic and judicial interventions (Delfieu, 2005). Mireille Lasbats, Ph.D., a clinical psychologist and forensic expert, published an article in an important legal journal, “Etude du syndrome d’alienation parentale ´ a partir d’une expertise civile” (“Study of the parental ` alienation syndrome starting from a civil expertise”). Lasbats described the identification of PAS in high-conflict divorces. With clinical cases she explained how to recognize this phenomenon and the risks to which the alienated child, as well as the rejected parent, are exposed. Consistent with Richard Gardner’s concept of PAS, Lasbats said the factors contributing to this condition are the manipulation by a parent and the contribution of the child to the denigration of the rejected parent (Lasbats, 2004). Also, Jacques Tremintin, M.A., a social worker, published an article, ´ “Quand l’enfant se retrouve pieg´ e—L’ali ´ enation parentale” (“When the child ´ finds himself/herself trapped—Parental alienation”). Tremintin said, “The ´ concept of parental alienation seems to be very helpful to better understand what is going on in certain families and work out intervention strategies for professionals” (Tremintin, 2005).

GERMANY A large number of German mental health and legal professionals have studied and commented on PAS. The first mention of “Parental Alienation Syndrome (PAS)” in the German professional literature was in 1995 by Wolfgang Klenner, Ph.D., a forensic psychologist, in an important article, “Rituale der Umgangsvereitelung bei getrennt lebenden oder geschiedenen Eltern” (“Rituals of contact refusal from parents in separation or divorce”). Klenner mentioned PAS—when a child has been heavily manipulated by one parent on whom it is dependent—as one of the possible causes of contact refusal (Klenner, 1995). In 1998, Ursula Kodjoe, M.A., a forensic psychologist, family therapist, and mediator, and Peter Koeppel, J.D., a family law attorney, published papers regarding PAS in Germany (Kodjoe and Koeppel, 1998a, 1998b, 1998c). These articles prompted an intensive discussion among mental health and legal professionals in Europe regarding the phenomenon of parental alienation and the diagnosis of parental alienation syndrome. Subsequently, Kodjoe said, “Experts need to have several theories and concepts at their disposal–amongst others, the PAS concept as an explanation for the refusal of contact for manipulative reasons. Experts who equate any form of contact refusal and the PAS concept did not understand the concept and must therefore reject it. The ‘estranged child’ is left out as a consequence. Manipulated against the other by the care-taking parent, seldom by the visiting parent and at the worst by both parents, the child internalizes the enemy image and behaves accordingly. This emotional abuse seems to be a taboo and is denied even by experts” (Kodjoe, 2003b). Walter Andritzky, Ph.D., a forensic psychologist and sociologist, studied PAS phenomena and published book chapters and articles in professional journals regarding this topic (Andritzky, 2002a, 2002b, 2002c, 2003a, 2003b, 2003c). He published two book chapters regarding PAS in English, “Behavioral Patterns and Personality Structure of Alienating Parents: Psychosocial Diagnostic and Orientation Criteria for Intervention” (Andritzky, 2003d) and “The Role of Medical Reports in the Development of Parental Alienation Syndrome” (Andritzky, 2006). Andritzky described the behavioral patterns of alienated children and the personality structure of alienating parents, as well as the “natural” and “induced” symptoms of children affected by high conflict separation or divorce. His articles assist professionals and institutions of the health and legal systems to understand the psychodynamic and diagnostic criteria of PAS and to make appropriate clinical and legal decisions in cases involving PAS. Wilfrid von Boch-Galhau, M.D., a psychiatrist and psychotherapist, and Ursula Kodjoe studied adult survivors of PAS in Germany. In a book chapter in English, they said, “The induction of PAS in the child must be considered a form of psychological/emotional abuse. It can be connected with traumatizing long-term effects in the child that endure into adulthood. It is dif- ficult to understand that this phenomenon—despite corresponding clinical findings and despite relevant results of recent traumatology and victimology research—is still trivialized, denied, or even opposed by many experts” (Boch-Galhau and Kodjoe, 2006b, p. 310). They also published their findings in a French journal, Synapse, Journal de Psychiatrie et Systeme Nerveux ` Central (Boch-Galhau and Kodjoe, 2006a). Also, Boch-Galhau, Kodjoe, Koeppel, and Andritzky organized the International Conference on PAS that was held in Frankfurt, Germany, in October 2002. Richard Gardner presented a lecture at that conference. The proceedings of this conference were published in their book, Das Parental Alienation Syndrom: Eine interdisziplinare Herausforderung f ¨ ur scheidungsbegleitende ¨ Berufe (The Parental Alienation Syndrome: An Interdisciplinary Challenge for Professionals Involved with Divorce) (Boch-Galhau et al., 2003). Information regarding this conference can be found on Astrid Camps, M.D., a child psychiatrist in Germany, said, “Gardner’s PAS concept proves helpful in child psychiatric practice. If the PAS problem for the child of divorce is not solved, the psychiatric and psychosomatic long-term consequences can be dramatic and for the child patient may be accompanied by great suffering (Camps, 2003, p. 155). Uwe Jopt, Ph.D., and Katharina Behrend, Ph.D., forensic psychologists from the University of Bielefeld, published a well known pair of articles regarding PAS. They described PAS as consisting of two stages. In the first stage, the specific conditions for the development of PAS are met (instrumentalization and parentification of the child, denigration of the other parent, with the custodial parent expecting the child to align to herself). In the second stage, the syndrome is solidified. There occurs a reduction of cognitive dissonance, a lack of empathy, internal and external reinforcement. The authors discussed possible methods of intervention by the various professions (family court, social services, psychological experts, and lawyers) (Jopt and Behrend, 2000a, 2000b). In Germany, mental health and legal professionals, institutions, and agencies use an important handbook, Kindesmisshandlung und Vernachlassigung (Child Abuse and Neglect) ¨ . This book refers to the “Parental Alienation Syndrome” as a particular kind of psychological violence against children in the context of custody and visitation conflicts (Deegener and Korner, 2005, pp. 684 and 694).

ISRAEL Daniel J. Gottleib, Psy.D., is a clinical psychologist who has served as a court-appointed expert in child custody and adoption cases. In a book chapter, Gottleib said, “In the Hebrew literature, PAS is referred to by different names: syndrome nikur hori (parental alienation syndrome), hitnakrut hehoreh (alienation from a parent), or sarvanut kesher (contact refusal). The differences in terminology do not reflect different theoretical approaches, … but rather all point to the same constellations of symptoms and dynamics that comprise PAS as described by Gardner” (Gottleib, 2006, p. 90).

ITALY Several mental health professionals in Italy have published articles, book chapters, and books regarding parental alienation. Apparently, the first person to write about PAS in the Italian professional literature was Isabella Buzzi, Ph.D., who is on the faculty of the Catholic University of Milan. Buzzi contributed a chapter regarding PAS to a comprehensive book, Separazione, Divorzio e Affidamento dei Figli (Separation, Divorce, and Child Custody) (Buzzi, 1997). In the following year, Guglielmo Gulotta published “La sindrome di alienazione genitoriale: Definizione e descrizione” (“The parental alienation syndrome: Definition and description”) (Gulotta, 1998). A psychologist, Roberto Giorgi, has written extensively regarding parental alienation, including a monograph, Le Possibili Insidie delle Child Custody Disputes: Introduzione Critica alla Sindrome di Alienazione Parentale di Richard A. Gardner (The Possible Pitfalls of Child Custody Disputes: Critical Introduction to Parental Alienation Syndrome by Richard A. Gardner) (Giorgi, 2005). Mario Andrea Salluzzo, a psychologist and psychotherapist, reviewed and summarized the work of Richard Gardner regarding PAS, and applied the concepts to several Italian cases. In a journal article, Salluzzo concluded, “For a therapeutic intervention, it is necessary that the legal personnel and the mental health professionals work in synergy. Only a clear and swift judicial action, aimed to discourage any attempt of sabotage by the alienating parent, can guarantee a good margin of success for psychotherapeutic or family mediation interventions” (Salluzzo, 2006). In 2005, an entire issue of a professional journal, Maltrattamento e Abuso all’Infanzia (Maltreatment and Abuse of Children) was devoted to PAS. The articles included “La sindrome di alienazione genitoriale (PAS): Studi e ricerche” (“The parental alienation syndrome (PAS): Studies and research”) (Malagoli Togliatti and Franci, 2005) and “La sindrome di alienazione genitoriale (PAS): Epigenesi relazionali” (“The parental alienation syndrome (PAS): Epigenesis of relationships”) (Malagoli Togliatti and Lubrano Lavadera, 2005). Marisa Malagoli Togliatti is a professor for the psychodynamics of child development and family relations at a distinguished institution, Sapienza Universita di Roma. ` There is a comprehensive, recent book from Italy regarding parental alienation, La Sindrome di Alienazione Parentale (PAS): Lavaggio del Cervello e Programmazione dei Figli in Danno Dell’altro Genitore (The Parental Alienation Syndrome [PAS]: Brainwashing and Programming of Children to the Detriment of the Other Parent). The authors include: Guglielmo Gulotta, a psychologist, lawyer, and professor of forensic psychology at the University of Turin; Adele Cavedon, a researcher in the Department of Psychology at the University of Padua; and Moira Liberatore, a psychologist, mediator, and lecturer at the University of Turin. They provide a complete and systematic description of PAS and its manifestations, generally based on the work of Richard Gardner, with a discussion of the differential diagnosis of PAS and related topics such as false memories and factitious disorder by proxy. These authors developed a method for identifying alienating behavior by means of microanalysis of communicative interaction and psycholinguistic analysis. This method involved the analysis of dialogue between the alienating parent and the child. They intended “to provide the various professional groups who encounter this perverse condition precise directions to recognize, diagnose, denounce, and take charge” (Gulotta et al., 2008)

JAPAN Colin P. A. Jones published an article, “In the Best Interests of the Court: What American Lawyers Need to Know about Child Custody and Visitation in Japan,” in the University of Hawaii Asian-Pacific Law & Policy Journal. He said, “Unfortunately, focusing on the problem as a cross-cultural one risks marginalizing it. In reality, parental child abduction and parental alienation are problems for parents and children in Japan, regardless of race or nationality. For every foreign parent who loses contact with their children in Japan, a greater number of Japanese parents suffer the same fate” (Jones, 2007).

MEXICO The First International Congress of Families was held in Mexico City in August 2006. The congress participants passed resolutions including the following: “It is important to stress that children should not suffer the consequences of separation or divorce of the parents. … Manipulating the children to create hatred or bitterness toward any of the parents, that is, parental alienation, should be avoided.” It was noted that the manipulation and brainwashing of children should be considered a form of child abuse. An international congress specifically regarding “S´ındrome de Alienacion Parental” took place ´ in June 2009 in Monterey, Mexico. Apparently, the legislature of the state of Queretaro, Mexico, has been ´ particularly proactive in recognizing the issue of parental alienation among divorced parents. The recently revised Civil Code of Queretaro states in ´ Article 396, “Whosoever exercises parental authority over a dependent minor ought to procure the establishment of a respectful and close relationship between said minor and the other adult exercising parental authority over this minor. Each adult exercising such parental authority over the minor must avoid any act of manipulation or parental alienation that may lead to feelings of resentment or rejection by said minor for the other adult” (Instituto de Investigaciones Jur´ıcas, 2009)

THE NETHERLANDS Ed Spruijt, Ph.D., at Utrecht University and his colleagues conducted quantitative research regarding PAS. They sent questionnaires to members of the Dutch Association of Family Lawyers and Divorce Mediators and also to a group of non-resident parents. Altogether they had 138 respondents from these two groups, and the authors “aimed to gain a first empirical impression of the phenomena of PAS in the Netherlands.” In conclusion, the authors stated, “Does parental alienation occur in the Netherlands? Our research con- firms that it does. Of the respondents to our questionnaire, 58% thought PAS does not occur, or hardly, in the Netherlands, whereas 42% thought it does occur” (Spruijt et al., 2005).

NORWAY In 1994, Richard Gardner introduced the concept of PAS to Norway when he spoke at a conference called “Seksuelle overgrep mot barn rettssikkerhet og rasjonalitet” (“Child Sexual Abuse, Justice and Rationality”). Part of Gardner’s lecture was later published in a book, Seksuelle overgrep mot barn: Et kritisk perspektiv (Child Sexual Abuse: A Critical Perspective), which was edited by Astrid Holgerson, Ph.D., and Lena Hellblom Sjogren, Ph.D. (1997). Probably ¨ the first description of parental alienation by a professional in Norway was an article by Jan Brogger, an anthropologist, who wrote, “N ¨ ar barn utvikler ˚ sykelig hat mot foreldre,” (“When Children Develop Morbid Hatred toward Parents”) (Brogger 1995). ¨ A psychiatrist in Oslo, Terje Torgersen, M.D., has published several articles regarding parental alienation. In an article called “Foreldrehatsyndromet” (“Parental Hate Syndrome”), he wrote, “If a residence parent frightens the child to reject contact with the other parent although he/she has visiting rights, this strategy will often be successful. As long as our politicians do not realize how serious the situation is, there is little hope for changes of the law (sole custody is still the norm)” (Torgersen, 1995b). In an article called “Samvaersrett og avmakt” (“Visitation Rights and Powerlessness”), Torgersen commented on the pathology often found in alienating parents. He wrote, “A lot of parents, sabotaging their children’s legitimate contact with the other parent, sadly enough have more or less disturbed personalities and are not capable of focusing on their children’s needs instead of their own. It is noteworthy that the society has not done more to help these children by reassuring them an actual right to have contact with both their parents” (Torgersen, 2008b). There have been additional publications in Norway regarding parental alienation and closely related topics. A Norwegian professor of psychology, Frode Thuen, published a book regarding children of divorced parents, Livet Som Deltidsforeldre (Life as a Part-time Parent). One of the chapters describes programming of a child to reject a parent without justified cause in connection with PAS (Thuen, 2004, pp. 91–121). Another important recent book was published by a Norwegian lawyer, Sverre Kvilhaug, a specialist in family law. This book, which discusses research regarding children separated from parents, was Atskillelse barn og foreldre, Hva internasjonal forskning sier om sammenheng mellom atskillelse I barndommen og senere fysiske og psykiske lidelser (Separation of Children and Parents: What International Research Says about the Relationship between Childhood Separation and Later Physical and Mental Disorders) (Kvilhaug, 2005). Finally, a Norwegian journalist, Ole Texmo, wrote a pamphlet on how to distinguish mild from serious parental alienation, which was based on a U.S. publication: Et langt og vanskelig ord Om metodisk pavisning av olike typer av foreldrefiendtliggj ˚ oring med refer- ¨ anse til Bone & Walsh (1999) kriterier for identifisering av PAS (Parental Alienation Syndrome) (A Long and Difficult Word: The Methodical Detection of Different Types of Parental Alienation with Reference to the Bone & Walsh [1999] Criteria for the Identification of PAS [Parental Alienation Syndrome]) (Texmo, 2007).

POLAND PAS has been observed in Poland and studied by senior academic psychiatrists. In Poland, PAS is called “Zespo´ł Gardnera” or “Gardner Syndrome.” Irena Namyslowska, M.D., Ph.D., the head of the Department of Child Psychiatry at the Institute of Psychiatry and Neurology, Warsaw, and her colleagues recently published an article in Psychiatria Polska. The title of the article was “Zespo´ł Gardnera—zespo´ł oddzielenia od drugoplanowego opiekuna (PAS). Rozpoznanie czy rzeczywistos´c rodzinna?” ´ (“Gardner Syndrome—Parent Alienation Syndrome (PAS). Diagnosis or family reality?”). The authors present characteristics of PAS, as described by Gardner, and they made suggestions for differentiating that syndrome from actual psychological, physical, and sexual abuse. The consequences of Gardner Syndrome for legal decisions in the court cases of child custody and the critique of this syndrome in forensic and psychiatric literature are also discussed, and several questions posed. They conceptualized PAS not as a disorder of the child, but as “a specific, dynamic family situation, which sometimes occurs during divorce and fights over child custody” (Namyslowska et al., 2009). Monika Dreger, a psychologist in Poland, also summarized the work of Richard Gardner. Dreger said, in effect, “[Gardner] described a disorder occurring in children, which in the course of the conflict, is involved in deprecation and criticism of one of the parents, but this kind of vilification is not justified and/or exaggerated. PAS can apply only if the children rejected a parent who is not the perpetrator of sexual, physical, or mental abuse against the children.” She concluded, “The most important thing is not to involve the child in conflict with the former partner” (Dreger, 2007).


UNITED KINGDOM Ludwig F. Lowenstein, Ph.D., has been a practicing psychologist in England for over 40 years. A prolific author, he has published over 400 articles and a dozen books, including articles and book chapters regarding PAS (e.g., Lowenstein, 1998, 2006a, 2006c). Lowenstein’s book, Parental Alienation Syndrome: How to Understand and Address Parental Alienation Resulting from Acrimonious Divorce or Separation, was published in 2007. Lowenstein addressed in detail the causes of parental alienation and possible treatment approaches. For example, he said, “The inducer of the implacable hatred holds the key to the child’s delusional beliefs of the absent parent. If this parent (with or without counseling) learns to self-reflect and stimulate the child in their relationship with the other parent, then the child’s delusional beliefs of the absent parent and their ‘evil and wicked ways’ can be eliminated. Often this is not the case and the custodial parent persists in promoting rejection of the absent parent in the child. Only by breaking the relationship between the inducer of such implacable hatred towards the absent parent can the child’s delusional beliefs be eliminated” (Lowenstein, 2007, p. 47). Tony Hobbs, J.P., L.L.M., a psychologist and researcher in family law, teaches at Keele University, England. In a book chapter, Hobbs said, “As PAS becomes more widely accepted, undoubtedly instances will arise in which false and/or malicious claims of children being inculcated into PAS are made. This may be regrettable but it should not be surprising, as it will only represent the converse of the many false claims of abuse that have become prevalent against PAS target parents” (Hobbs, 2006b, p. 89).

Cloud 11 (1)


Perhaps one of the most extreme, poignant, and damaging cases that exemplify how article 13(b) of the Hague Convention Treaty creates a loophole for PAS, through which, in severe cases, children are lost to the alienated parents, n61 is the case of Lady Catherine Meyer.

She has written two books about her ordeal: Two Children Behind a Wall n62 and They Are My Children, Too. n63 n61 DARNALL, supra note 39, at 13, 14. n62 CATHERINE LAYLLE, TWO CHILDREN BEHIND A WALL (1997). n63 CATHERINE MEYER, THEY ARE MY CHILDREN, Too (1999).

In Sept. 1998, Lady Meyer went on to help organize, with the National Center for Missing and Exploited Children (NCMEC), the first International Forum on International Child Abduction.

A few months later, again with NCMEC, Lady Meyer co-founded theInternational Centre for Missing and Exploited Children (ICMEC). Lady Meyer has been invited to give evidence to committees of the U.S. Senate and House of Representatives.

Lady Meyer also testified before the Belgian Senate. In Mar. 2000, Lady Meyer and a group of American parents created PACT (Parents of Abducted Children Together). Their successful representation led President Clinton to raise the issue with Chancellor Schroeder of Germany on June 2, 2000.

In 1994, at the time that her two sons, Alexander (then nine years old) and Constantin (then seven years old) were abducted by her husband, Dr. Hans-Peter Volkmann, Lady Meyer was Catherine Laylle. During Catherine Laylle’s unrelenting determination to get her two sons back, she met the (then) British ambassador to Germany, Sir Christopher Meyer. As a result of the abduction of her two sons, Catherine Laylle was physically, emotionally, and financially depleted. Through Sir Meyer’s efforts to help Catherine Laylle, the two became very close. When Sir Meyer was offered the post of British ambassador to the United States, Catherine Laylle joined him in Washington as his wife and became Lady Catherine Meyer.

This case history began in 1984, when Lady Meyer (who is of French-Russian descent) married a German medical doctor, Volkmann, in London. Their first son, Alexander, was born in London a year later. Their second son, Constantin, was born in Germany in 1987. The marriage broke up in 1992, and the couple were legally separated. The children lived in London with Lady Meyer and visited their father during their school holidays.

On 6 July 1994, the children left for their summer holidays with their father. Without warning, four days before they were due to return to London, Dr. Volkmann announced that he was not 13 sending them back to England. He then disappeared with the boys. n65 Lady Meyer received a twenty-one-page letter from Dr. Volkmann, which stated in pertinent part, click here to read the full story

The Spread of Animosity to the Extended Family and Friends of the Alienated Parent

The hatred of an alienated parent often extends to include that parent’s complete extended family. Cousins, aunts, uncles, and grandparents – with whom the child previously may have had loving relationships – are now viewed as similarly obnoxious.

Grandparents who previously had a loving and tender relationship with the child find themselves suddenly and inexplicably rejected.

The child has no guilt over such rejection, nor does the alienator.

Greeting cards are not reciprocated. Presents sent to the child are refused, remain unopened, or are even destroyed (generally in the presence of the programming parent).

When the denigrated parent’s relatives call on the telephone, the child will respond with angry vilification or quickly hang up on the caller. (These responses are more likely to occur if the alienating parent is within hearing distance of the conversation.)

With regard to the denigration of the relatives, the child is even less capable of providing justification for the animosity.

The rage of a PAS child is often so great that he becomes completely oblivious to the privations he is causing himself.

Again, the indoctrinating parent is typically unconcerned with the untoward psychological effects on the child of this rejection of the network of relatives who previously provided important psychological gratification.

Divorce Poison


The Pathology of an Obsessed Alienator 

click on link to view presentation.

Therapeutic Treatment for PAS

Linda Gottlieb, LMFT, LCSW in her book: The Parental Alienation Syndrome: A Family Therapy and Collaborative Systems Approach to Amelioration

*Individual Therapy is a waste of time

*Only trained family therapists can correct this, as it is a family system’s problem

*The Healing has to be done in the context of the relationship with the alienated parent.

* Treatment Progress happens much more quickly when the Alienating parent is on board, usually by courtorder.

“Alienation is your call to evolve to become the kind of person who can be calm in the face of the worst kind of abuse. Think of Martin Luther King’s lunch counter children. Think of the violence, degradation, and abuse such pioneers on the forefront of a cause faced.

You are on the forefront of a newly discovered form of intentional, highly targeted marginalization, organized prejudice and discrimination.

The question becomes: ‘How will YOU rise to the occasion’?”

Love Yourself

Judge Michele Lowrance, Parental Alienation 911 Workbook, 2012, p.58

Dr. William Bernet – 3 levels/stages Parental Alienation

Dr. William Bernet of Vanderbilt University describes the three stages or levels of Parental Alienation including Yellow, Orange, and Red categories. His list is combined below with Dr. Douglas Darnall’s description of three categories of Parental Alienation, including Mild, moderate and severe.

(Yellow) Mild: The child may briefly resist contact with the alienated parent, but does have contact and enjoys a good relationship with the targeted parent once they are together. When it is mild, the child may have a strong, healthy relationship with both parents, even though the children recites criticisms of the alienated parent. The alienator is usually naive. The alienators are ignorant of what they are doing and are willing to be educated and change.

(Orange) Moderate: The children may persistently resist contact with the alienated parent and will continue to complain and criticize the alienated parent during the contact. The child is likely to have a mildly to moderately pathological relationship with the preferred parent. The alienating parent is an active alienator. When they are triggered, they lose control of appropriate boundaries. They are volatile and lose control, but won’t admit it.

(Red): Severe: The child strongly and persistently resists contact and may hide or run away to avoid seeing the alienated parent. The child’s behavior is driven by a firmly held, false belief that the alienated parent is evil, dangerous and or worthless. The child is likely to have a strong, severely pathological relationship with the preferred parent, perhaps sharing a paranoid worldview. The alienating parent is obsessed with breaking down the attachment between the target parent and child. They come from a delusional system where they are committed to destroying the relationship and doing a “parentectomy” of the targeted parent


Dr. J. Kelly

“Because it is anti-instinctual to hate and reject a parent, the child must develop an elaborate delusional system consisting of spurious, frivolous, and absurd rationalizations to justify the hatred and rejection.

Eventually, the child comes to believe all the absurdity. The double-bind situation of being unable to have, love, and to be loved by both parents can lead to psychosis.”

Cloud 4 (5)

Dr. Burkhard, co-founded Child and Family Psychological Services

“These children do not follow rules; they are out of control; they are basically naughty and lack limits. These children behave as if they have license to do whatever they want. It may have begun as a breakdown in not having to respond to for the authority of and respect for the other parent. In the cases of treatment or court failure to reunite, we have seen the lack of respect for authority figures including the favored parent, school, and the law. Among the cases where reunification efforts have failed are children who have dropped out of school, become addicted to drugs, born children out of wedlock addicted to drugs, and engaged in other antisocial behaviors. This is not a good outcome.”

“Childhood is a time to develop a sense of responsibility. It is a time to develop a conscience. Children who become alienated have this fundamental aspect of their development derailed. They are not only not held accountable for their mistakes and misdeeds, they may be encouraged to tell lies or exaggerate the truth, and otherwise act in ways that are disrespectful of others. that these behaviors are reinforced by a trusted parent further undermines normal moral development as well as the development of their ability to develop normal relationships.”

Love Yourself

Effects On The Child

They learn to please others and care-take their victim parent.

Their growth is stunted as they are surviving, not safe enough to develop properly.

They learn it’s okay to lie and keep secrets.

They learn to be manipulative and exploit others.

They learn to suppress their emotions.

They learn to hate themselves. Often ending up with substance abuse problems, low self esteem, early pregnancies, relational problems.

They are not happy.

They have hidden grief.

They are emotional reasoners, not critical thinkers.

It is not reinforced for them to think for themselves.

They are kept dependent on the alienating parent.

They are afraid of abandonment.

They want the love and approval of the alienating parent and often trauma bond with them.

They have a selective attention filter to only see the bad in the targeted parent and only the good in the other parent.

They show no guilt or remorse.

They lack of gratitude for gifts.

They have suppressed guilt for treating their parent badly.

They are vulnerable to depression and learned helplessness.

They are being emotionally abused