INTRODUCTION

The Parental Alienation Syndrome (PAS) is a controversial theory which has had a profound influence on how child custody cases are handled by the legal system. PAS is based on the assumption that if a child rejects their father, the most likely cause of the alienation is the mother. Treatment involves separating the child from their mother, and punishing them both until the child cooperates with visitation. Richard A. Gardner, M.D., a clinical professor of child psychiatry at the College of Physicians and Surgeons at Columbia University , is the founder and main proponent of this theory.

PAS has been the focus of ever-expanding attention since Gardner ‘s first publications on the disorder in the mid-1980s. PAS quickly became a popular defense against accusations of abuse that were raised during custody disputes. This defense became so successful that some courts awarded men alleging alienation sole custody of their children, even when abuse allegations were deemed credible. Recently some men have leveled accusations of PAS against their wives as a means of gaining sole custody in cases where no abuse accusations were ever raised. Some women have even lost custody of their children because a psychologist has suggested they might become an alienator at some point in the future. For instance, Maria Duncan, a 44-year-old Stanford graduate who lives in Los Gatos, California, lost custody of her daughter to her ex-husband – a convicted batterer – after a court-ordered psychologist said Duncan had a “grudge toward men” and might become an alienator in the future (Goldsmith, 1999).

This article examines the scientific support for PAS along with its underlying assumptions and logic. This theory’s relevance to child abuse allegations that arise during child custody disputes is also explored.

Parental Alienation Syndrome

According to Gardner (September 6, 1993), PAS is “a disorder of children, arising almost exclusively in child-custody disputes, in which one parent (usually the mother) programs the child to hate the other parent (usually the father).” The child then becomes an active participant and joins the programming parent with their own scenarios of “denigration.” According to Gardner (1992a, p. 59), 90% of alienators are women. Gardner (1991, p. 24) claims “irate” mothers have found false sexual abuse allegations to be powerful weapons against their “despised” husbands. According to PAS theory, mothers use such allegations to win custody, to cut off the father’s visitation, or to wreak vengeance on their former spouse. Gardner (1987, p. 274) claims that PAS is responsible for most accusations of child sexual abuse that are raised during custody disputes, and that “in custody litigation . the vast majority of children who profess sexual abuse are fabricators.” Moreover, Gardner (Spring 1991, p. 16) suggests that when a woman accuses her husband of molesting their child, she may be projecting her own sexual inclinations onto him.

Gardner (1987, p. 67) asserts that PAS has become increasingly common and he now sees manifestations of this syndrome in over 90% of the custody conflicts he evaluates – even when abuse allegations are not raised. Gardner (1998) states: “My experience has been that the sex-abuse accusation does not appear in the vast majority of PAS cases.”

Gardner (Spring 1991, p. 21) believes that the legal system should change the standard for determining custody from the best interests of the child to a “healthy psychological bond” presumption. Under this presumption, preference would be given to the parent who has the healthiest psychological bond with the children, as determined by an examiner trained in Gardner ‘s theories. Gardner (1998) suggests that PAS should be “considered a serious deficit in parenting capacity – a form of emotional abuse – and that it be given serious consideration when weighing the custody decision.” Because PAS theory blames problems in the father’s relationship with the child on the mother, PAS is remedied by increasing the child’s contact with the father while reducing their contact with the mother.

Gardner (Spring 1991, p. 17) believes that judges should back up PAS-trained therapists’ conclusions with the full force of the law and impose fines, permanent loss of custody, and jail terms for mothers who do not comply. Treatment of noncompliant children involves placing them in either a juvenile detention center or a foster home for a few days to reconsider their decision ( Gardner , 1999). Treatment of severe pathology involves strictly enforced separation between mother and child. Gardner (May 1992, p. 2) asserts that “it is crucial that there be no contact at all [emphasis in original] between the children and their mother, either directly or indirectly, e.g., via telephone or mail.” [1]

The Foundation of PAS Theory

PAS is not based on systematic research; rather, Gardner (1987) developed this theory through his personal observations and work as an expert witness. Since the support for PAS has invariably been Gardner ‘s writings, it is important to examine Gardner ‘s beliefs and assumptions concerning children. Specifically, Gardner ‘s views on both pedophilia and sexual abuse must be examined, as these views form the context for Gardner ‘s observations during custody evaluations. It is also important to examine the instruments that Gardner developed to differentiate valid from false allegations of abuse – the Sex Abuse Legitimacy Scale (SALS) and Protocols for the Sex-Abuse Evaluation – as they are derived from the same theoretical framework as PAS.

Gardner ‘s Views on Pedophilia [2]

Gardner (1992b, pp. 670-71) considers sexual activities between adults and children to be part of the natural repertoire of human sexual activity and suggests that pedophilia may enhance the survival of the human species by serving “procreative purposes” (1992b, p. 24-5). According to Gardner (1992b, p. 593), “pedophilia has been considered the norm by the vast majority of individuals in the history of the world” and “it is a widespread and accepted practice among literally billions of people.”

In addition, Gardner (1986, p. 93) believes that children are naturally sexual and may initiate sexual encounters by “seducing” the adult. Moreover, Gardner (1992b, pp. 670-71) maintains that sex abuse is not necessarily traumatic; the determinant as to whether sexual molestation will be traumatic to the child, is the social attitude toward these encounters. Accordingly, Gardner (1992b, pp. 593-4) believes that our society takes an excessively punitive and moralistic attitude toward those who act out their pedophilic impulses. In fact, Gardner (1991, p. 26) suggests that “all of us have some pedophilia within us.”

It should be noted that Gardner’s views on pedophilia are at odds with the scientific research on child sexual abuse which has consistently and conclusively shown the negative long-term effects of sexual abuse on children’s lives (e.g., Fergusson, Horwood, & Lynskey, 1996; Johnson, Cohen, Brown, Smailes, & Bernstein, 1999; Silverman, Reinherz, & Giaconia, 1996).

Gardner ‘s Views on Child Sexual Abuse

Notwithstanding his training as a child psychiatrist, Gardner ‘s writings and expert testimony usually benefit those accused of molesting children rather than the children involved in these cases. And despite his view that the vast majority (“probably over 95%”) of all sex abuse allegations are valid (Gardner, 1991, pp. 7, 140), Gardner has spent much of his career crusading against what he considers to be an epidemic of false accusations that is sweeping our country. Gardner (1992b, p. 688) states: “I believe it is reasonable to say that at this time there are millions of people in the United States who are either directly accusing or supporting false sex-abuse accusations and/or are reacting in an extremely exaggerated fashion to situations in which bona fide sex abuse has occurred.” To deal with the present “hysteria” over child sexual abuse, Gardner (1991, p. 120) suggests that society should “`come off it’ and take a more realistic attitude toward pedophilic behavior.” To this end, Gardner (1993; 1995a) calls for abolishing mandated reporting of child abuse, doing away with immunity for reporters of child abuse, and has lobbied for the creation of federally funded programs to assist those who claim to be falsely accused.

Sex Abuse Legitimacy Scale

Gardner (1987) developed the Sex Abuse Legitimacy Scale (SALS) in concert with his PAS theory as a means of differentiating true from false accusations of child sexual abuse, particularly during custody disputes. Because Gardner believes that most accusations of child sexual abuse that are raised during custody disputes are false, the SALS relies heavily on PAS theory in making determinations of abuse. Answers are awarded a varying number of points, depending on how valuable Gardner considers the criteria. Gardner set an arbitrarily high threshold before findings would register as suggestive of actual sexual abuse in order to minimize the possibility of a false accusation.[3]

The SALS emphasizes the importance of the examiner having full access to all concerned parties: the child, the accuser, and the alleged perpetrator. Joint interviews with the child and the alleged perpetrator may play a part in these evaluations since, according to Gardner (1988, p. 62), “The alleged perpetrator is in a far better position to cross-examine the accuser than even the most astute and knowledgeable attorney.”

The SALS was rejected by a Florida appellate court ( Page v. Zordan , 564 So.2d 500, 1990) because there was no “reasonable degree of recognition and acceptability among the spectrum of scientific or medical experts” (Sherman, 1993, p. 45). It was subsequently withdrawn from the market by Gardner, who says that he discontinued utilization of the Scale due to its widespread misuse (Chenoweth, 1993). Although the SALS has been widely discredited, Gardner has not modified his PAS theory on which the SALS was based. Gardner (1995b) subsequently presented a revised checklist to differentiate between true and false allegations of sexual abuse in his book Protocols for the Sex-Abuse Evaluation . The Protocols include most of the items in the SALS, and PAS again figures prominently as a signal that the abuse allegation is false.

Conceptual Problems with PAS Theory

The purpose of a theory is to explain phenomena and predict outcomes. To be considered scientific, a theory must be based on systematic empirical observations, reasonable assumptions and logical reasoning. The theory must then be tested under controlled conditions. If the theory is supported, it gains credibility and continues to evolve as better data becomes available. If the theory is not supported, it is either abandoned or significantly revised.

In contrast, PAS theory has remained essentially stagnant for the past 15 years. Gardner has never tested his theory and over the last decade most of PAS’s foundational assumptions have been disproven. Moreover, PAS theory has been criticized for numerous conceptual weaknesses including not being logical, being biased, and for failing to take into account alternative explanations for children’s and parents’ behavior in custody cases. Unfortunately Gardner has neither rejected his theory or significantly revised it in response to new data and criticism from his peers. As a result, PAS theory has taken on the qualities of ideology rather than science.

Reliance on Circular Reasoning and Reverse Logic

Critics have faulted Gardner ‘s theories for their reliance on circular reasoning and reverse logic, particularly in making determinations of abuse (e.g., Rotgers and Barrett, 1996). An example of reverse logic can be found in Gardner ‘s argument that the vast majority of sexual abuse allegations raised during custody disputes are false. However, one of Gardner ‘s more heavily weighted criteria for determining that an accusation is false is the fact that allegation was first raised during a custody dispute (Sherman, 1993, p. 45). Other criteria defy logic; for example, the fact that a child accuses a parent of sexual abuse is used as evidence of PAS, which is then considered a very valuable criteria in determining that the abuse allegations are fabricated. Thus, the fact that the child or mother raises an allegation is used as proof that the allegation is false.

Kathleen Coulborn Faller (1998), a professor of social work at the University of Michigan , points out that virtually every symptom described by Gardner as evidence of PAS is open to opposing interpretations. For example, PAS only explains the behavior of the child and the mother if the child has not been sexually abused. If the child has been abused, then both the child’s animosity toward the father, and the mother’s attempts to obstruct visitation would not only be warranted, but would be expected of a good parent. Gardner concedes this point.

In March 1991, Gardner began inserting an addendum in his 1988 book The Parental Alienation Syndrome which stated: “Unfortunately, the term parental alienation syndrome is often used to refer to the animosity that a child may harbor against a parent who has actually [emphasis in the original] abused the child, especially over an extended period.When bona fide abuse does exist, then the child’s responding hostility is warranted and the concept of the parental alienation syndrome is not applicable.”

After reading this admission, an important point should be evident: the tools which Gardner developed to differentiate true from false allegations – the SALS and later the Protocols –are based on the concept of PAS. Because Gardner states that the concept of PAS is not applicable to children who have actually been abused, the evaluator would have to determine beforehand that the allegation of sexual abuse was false in order to use Gardner ‘s tools for determining abuse. Thus both PAS and the Protocols are seriously flawed by their reliance on circular reasoning and a priori determinations.

Erroneous Assumptions

Assumptions are the building blocks of theories and are basically educated guesses which are accepted on faith or are assumed to be true. If the assumptions that a theory is predicated upon are determined to be false, the theory is weakened and should be reconsidered. While PAS theory has never been formally tested, most of the assumptions on which it is based have proven to be false, calling the whole theory into serious question.

PAS theory is predicated on the following false assumptions:

1. There is an epidemic of sexual abuse allegations being made by mothers against fathers during custody disputes.

Although there is little doubt that an increasing number of parents caught up in custody litigation raise the possibility of sexual abuse, there is no evidence that the number of allegations is spiraling out of control. In fact, compared to the prevalence of child abuse in our society, abuse appears to be under-reported in custody disputes (McDonald, 1998).

Most conflicts around custody and access are resolved by the parents themselves outside court. According to Department of Justice statistics (May 1990), only 3.8% of all custody and access cases are finalized through contested hearings. When contested cases have been examined, sexual allegations have proved to be uncommon. Thoennes and Tjaden (1990) of the Association of Family and Conciliation Courts Research Unit in Denver, gathered data from domestic relations court staff in 8 jurisdictions during a 6-month period. More than 9,000 families in these areas had custody or visitation disputes. Of these 9,000 disputes, less than 2% involved allegations of sexual abuse. This finding was replicated in another area of the country by McIntosh and Prinz (1993) who also found sexual abuse allegations in only 2% of 603 cases in which custody or access was contested. Not only has no epidemic of sexual abuse allegations been found, when allegations are raised, mothers accused biological fathers in less than half of the cases (Thoennes and Tjaden, 1990).

2. The majority of sexual abuse allegations that arise during custody disputes are false.

Gardner ‘s contention that the majority of sexual abuse allegations that arise during custody disputes are false has also been disproven. Research has shown that between 50 and 75% of allegations raised during custody disputes are judged to be valid.

For example, both Hlady and Gunter (1990) and Thoennes and Tjaden (1990) found that accusations of child sexual abuse made during custody disputes are just as likely to be substantiated as allegations in non-custody related situations. Paradise , Rostain and Nathanson (1988) examined abuse allegations made within the context of a custody or visitation dispute and compared these cases to ones in which custody or visitation was not an issue. They found that sexual abuse allegations were substantiated slightly less frequently when there was concomitant parental conflict; however, they were nevertheless substantiated more than half of the time. Jones and Seig (1988) reviewed 20 consecutive cases involving both sexual abuse allegations and a parental custody dispute. They found 70% of the cases were judged reliable and 20% appeared fictitious. Faller (1991) reviewed 136 divorce cases involving child sexual abuse allegations. Over 75% of the allegations were considered valid, with a variety of dynamics leading to the allegations. In the majority of the cases examined, the marital dissolution precipitated the sexual abuse, or children revealed long-standing sexual abuse during the marital breakup.[4]

Sink (1988) lists 4 reasons why valid disclosures may arise during divorce or custody disputes.

1. Some children may have less contact with an abusive parent and feel less threatened or inhibited about revealing secrets.
2. Some children may have more time alone with the abusive parent and a heightened sense of vulnerability may result in a disclosure by the child.
3. The stress and anxiety of the divorce may increase the closeness between the child and a family member in whom they decide to confide secrets about how the family used to be.
4. A parent may not have been abusive before, but under the stress of the divorce may turn to the child for nurturance and affection.

For more information on the veracity of child sexual abuse allegations that arise in the context of child custody disputes, see the Appendix.

3. The majority of false accusations are made by “vengeful wives” who are trying to deny their husband custody.

There is no evidence to support Gardner ‘s contention that the majority of false accusations are made by women maliciously attempting to deny their husband custody or visitation. Although women report sexual abuse more frequently than men, it should be remembered that 95% of sexual abuse against girls and 80% of abuse against boys is perpetrated by men (Finkelhor, 1984), so it makes sense that women would report abuse more frequently.

However, in spite of the fact that women report more abuse, they do not appear to be responsible for most false allegations. Researchers at Queen’s University reviewed judges’ decisions in 200 cases between 1990 and 1998 where allegations of either physical or sexual abuse were taken to court. The study showed that the judges felt that only a third of unproven cases of child abuse stemming from custody battles involved someone deliberately lying in court. In these cases, the judges found that fathers were more likely to fabricate the accusations than mothers (Ayed, 1999).

4. Abusive or neglectful parents behave in a stereotypic and readily apparent manner

Gardner (1999) recently developed guidelines for differentiating PAS from bona fide abuse during a custody disputes. In his writings, Gardner groups parents who physically abuse, sexually abuse, or neglect their child into a single category – suggesting that abusive and neglectful parents  present in a similar psychopathic fashion and provide a similar history to an evaluator. For instance, Gardner (1999, pp.105-6) suggests that “abusive-neglectful” parents are impulsive, “they are quick to fight” and commonly have a history of job loss. According to Gardner, these parents “do not strive to be high earners and often will spend their earnings elsewhere; for example, alcohol or gambling” (p. 105).[5] Gardner further suggests that fathers who abuse their children will generally abuse their wives as well.

It should be noted that research counters Gardner ‘s stereotypical portrayal of physically or sexually abusive males. Contrary to Gardner ‘s assertions, men who abuse or neglect their children come from all socioeconomic groups and many function quite well outside of the home. Moreover, there is no research that supports a single personality profile for parents that perpetrate any specific form of abuse much less all types of abuse and neglect. For instance, research has found that no single typology characterizes violent men in terms of pathology or general personality (Schuerger & Reigle, 1988). Likewise, there is no personality profile or marital pattern that is prototypical of incestuous fathers (Smith, & Saunders, 1995). Moreover, when confirmed incest perpetrators have been compared with matched controls, researchers have found no difference for levels of marital adjustment or overall psychopathology between the two groups (Dadds, Smith, Webber, & Robinson, 1991).

Many batterers are charming and well behaved outside of the home. The same is true of pedophiles. Singer, Hussey and Strom (1992, p. 884) note that “Contrary to popular belief, sexual offenders are not often unskilled and inept, rather they are frequently quite sophisticated, calculating and patient.”

5.  By using Gardner’s criteria, an evaluator can tell if a parent has abused or neglected their child.

Although, Gardner (1999) suggests that an interview will reveal whether a parent is an abuser or not, forensic psychologist Douglas Darnall (1998) suggests that attempting to make such a judgment is a misuse of psychological evaluations. Darnall (1998) notes, “Unless there is an admission by the abuser, the evaluation cannot conclude whether a person had or had not abused anyone.” Moreover, research has shown that psychiatrists perform no better than chance when attempting to detect lying (Ekman & O’Sullivan, 1991).

6. PAS theory assumes that a woman who is assertive or self-protective is an alienator.

Although Gardner (1999) believes if the child was abused then the mother probably was also abused (another unsupported assumption), he does not take her victimization into account when evaluating her behavior. For example, he suggests that non-alienating (i.e., good) mothers will do “everything in their power” to savage the relationship between the child and an abusive father. However, these assertions fail to acknowledge the valid fears that a woman might have for herself or her child’s safety. It should be noted that research has found that when a woman tries to leave her abuser, the violence often escalates and is more likely to become lethal. For instance, the Canadian Panel on Violence Against Women Survey (1993) found that battered women who are separated from their partners are approximately five times more likely to be killed than other women. It seems unrealistic to expect a women who fears for her life, or for her child’s safety, to do everything in her power to maintain contact with an abusive man.

Gardner also fails to take into account the psychological after-effects of being battered. For instance, a study of battered women found that over half of them (58%) had Posttraumatic Stress Disorder (PTSD) (Astin, Ogland-Hand, Coleman, & Foy, 1995). PTSD is a disorder in which is characterized by intrusive memories, avoidance of stimuli reminiscent of the trauma, and hyperarousal. Hyperarousal may cause people with PTSD to experience intense fear, anxiety, anger and panic in response to even minor stimuli. However, Gardner ‘s guidelines are written in such a way that an unwary examiner might mistake a woman’s fear and anxiety for PAS. For example, if a woman appears distrustful and or protective of herself or her child, an evaluator trained in Gardner’s techniques would tend to characterize her as paranoid and uncooperative – qualities which Gardner considers to be strong indicators  that the woman is a “PAS inducer” (1999, p. 107).

Gardner also suggests that rage is an indicator that a woman is an alienator. Gardner (1999, p. 102) states: “In extreme cases it appears that the alienating parent would be pleased if the alienated parent were to evaporate from the face of the earth.” However, a recent article in Court Review , a journal for judges, states: “One can pose the question of what would be a normal response to the information that one’s child had been raped or molested. Rage seems to be a pretty `normal’ response” (McDonald, 1998, p. 19).

The mischaracterization of women’s behavior and motives during custody disputes has become a large enough problem that the APA’s Presidential Task Force on Violence and the Family (1996) addressed this in their report on family violence. The document states: “If the court ignores the history of violence as the context for the mother’s behavior in a custody evaluation, she may appear hostile, uncooperative, or mentally unstable. For example, she may refuse to disclose her address, or may resist unsupervised visitation, especially if she thinks her child is in danger.” The APA further notes: “Psychological evaluators who minimize the importance of violence against the mother, or pathologize her responses to it, may accuse her of alienating the children from the father and may recommend giving the father custody in spite of his history of violence.”

Another criteria worth noting (mainly because it appears to be self-serving), is Gardner’s (1999) assertion that resisting the impartial examiner picked by the alleged abuser or objecting to paying high fees for such an examination is a sign that the woman is an alienator. Gardner (1999) asserts that alienators “typically resist the targeted parent’s attempts to bring in an impartial examiner; rather, they seek a mental health professional who is naive enough to be taken in by their often-deceitful maneuvers .. It is the alienated parent who is more likely to be willing to make the financial sacrifices to bring in competent mental health examiners to do assessments.” It should be noted that Gardner generally represents men, considers himself to be impartial,[6] and is reported to charge $500 per hour (Goldsmith, 1999). In creating these criteria, Gardner seems to be suggesting that if an accused abuser hires him and the wife does not agree to his “impartial” examination or agree to help pay his fee, then she will be judged to be an alienator. It should be noted that no such criteria is applied to the allegedly abusive man. Apparently he is free to resist the accused alienator’s choice of evaluators without any negative judgment.

7. If a child is alienated from one parent, it is the other parent’s fault.

Gardner does not acknowledge the complexities of family dynamics or explore alternative explanations for a child’s alienation. This is one of the most serious deficiencies found in PAS theory and will be explored in depth in the next section.

Alternative Explanations are not Considered

Critics point out that the concept of PAS emphasizes the psychopathology of the favored parent, while failing to take into account the many alternative causes for the family dynamics observed in custody disputes. For instance, PAS assumes that a child’s rejection of their father is caused by brainwashing by the mother without exploring the father’s possible contribution to problems in his relationship with his children.

Children are not born with genes that program them to reject a father. Such hatred is environmentally induced, and the most likely person to have brought about the alienation is the mother. (Gardner, 1992a, p. 75)

Psychologist Benjamin D. Garber (1996) notes that PAS theory confuses cause and effect and cautions that it is very easy for a presumption of alienation “to take on a life of its own without proper consideration of the many alternative (and often more likely) causes of a child’s distress during parental separation and divorce.”

Observing, for example, that Johnny refuses to go on visits with dad, curses his name, or becomes obviously anxious in his presence is not sufficient grounds for concluding that his mother is actively alienating the child. To jump to this conclusion without first ruling out alternative causes of the child’s distress is to potentially harm the child and one or more of his caregivers in ways which . may be profound and long lasting. (Garber, 1996, p. 52)

Garber cites research which has found that the best predictors of a child’s distress and dysfunction during and after parental divorce is the child’s age, the degree of emotional security present within the home prior to the parental separation, and the degree of conflict witnessed by the child. Garber, (1996, pp. 52-4) notes that ambivalence or rejection of a parent may be related to many different factors including: (1) normal separation anxiety; (2) child abuse and neglect; (3) the parent’s inappropriate behavior or expectations; (4) inappropriate, unpredictable or violent behavior by the parent; (5) “incidental causes” such as dislike of a the parent’s new roommate or lover; (6) alienation via third parties; (7) the child’s unassisted manipulation of their parents; and (8) fears for the absent parent’s welfare.

Forensic psychologist Kenneth H. Waldron and family law attorney David E. Joanis believe that PAS is an actual phenomenon, but are critical of Gardner ‘s “simplistic” conceptualization of this complex family dynamic.

Gardner ‘s conceptualization of the problem [PAS] and the dynamics underlying the problem proved at best incomplete, if not simplistic and erroneous. He portrays the alienating parent as virtually solely responsible for the dynamic, turning the vulnerable child against the innocent target parent. More extensive research on this topic has more clearly established the complex involvement and motives of all the actors in this disastrous family drama. (Waldron & Joanis, 1996, p. 121)

Waldron and Joanis point out that children may reject a parent following a parental separation for many reasons, not all of which reflect PAS. Sometimes the child rejects a parent based on the child’s actual experiences with that parent. The rejected parent may have substantial weaknesses in parenting, be violent or insensitive to the child’s needs, have psychological or emotional problems, or have abandoned the child. However, the rejected parent typically has limited insight into his or her own contributions to the alienation. Waldron and Joanis (1996, p. 122) note that when present, “PAS is not just the work of the alienating parent.” PAS “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 efforts of others at correction.”

Mary Lund (1995, p. 309), a psychologist and consultant for the Los Angeles Superior Court Family Law Department, states: “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.” Lund notes that most PAS cases do not have one parent who is much more psychologically healthy than the other. According to Lund (1995, pp. 309-11), many problems contribute to estrangement between a parent and child. These include: (1) developmentally normal separation problems; (2) deficits in the noncustodial parent’s skills; (3) oppositional behavior; (4) high-conflict divorced families; (5) serious problems, not necessarily abuse; and (6) child abuse.

Problems with Bias

Critics have noted that Gardner ‘s methods for determining the veracity of an abuse allegation are seriously biased in favor of the alleged child molester. Lisa Amaya-Jackson, M.D., Assistant Professor of Psychiatry and Medical Director of Child and Adolescent Trauma Treatment Services at Duke University, and Mark D. Everson, Ph.D., Clinical Associate Professor in Psychiatry and Director of the Program on Childhood Trauma & Maltreatment at University of North Carolina Hospitals, Chapel Hill, reviewed Gardner’s book Protocols for the Sex-Abuse Evaluation and found Gardner’s system for detecting sexual abuse in children to be “seriously flawed.”

Amaya-Jackson and Everson (1996) state: “Bias can be noted in the author’s attempts to discredit a child’s allegations by resorting to narrow, often oversimplified notions of how sexually abused children are supposed to behave.” They further note that while he discusses the importance of evaluators being neutral and objective, Gardner conveys “a strong bias that the overwhelming majority of allegations, especially in custody-related cases, are false and that the assessment procedures the author advocates are slanted to arrive at such a conclusion.” Amaya-Jackson and Everson (1996) conclude: “This book can perhaps best be described as a recipe for finding allegations of sexual abuse false, under the guise of clinical and scientific objectivity. One suspects that it will be a bestseller among defense attorneys.”

Critics have also faulted Gardner’s theories for being biased against women.[7] McGeorge Law Professor John E. B. Myers (1997, p. 137) states: “In my opinion, much of Gardner’s writing, including his discussion of his parental alienation syndrome, is biased against women. This gender bias infects the syndrome and makes it a powerful tool to undermine the credibility of women who allege child sexual abuse.”

Under Gardner ‘s theories, women who complain or challenge a judge’s ruling to place the child with an alleged abuser tend to be inappropriately labeled as mentally ill. Susan Penfold (1997, p. 26), a professor of Child Psychiatry at the University of British Columbia, notes that during custody disputes many men minimize their responsibility for the martial breakdown by

pathologizing their ex-wives and presenting themselves as the rational, reasonable and logical parent. In this context, raising concerns about child sexual abuse tends to galvanize men and their lawyers to present a scenario that glorifies the father’s parenting abilities while stressing the woman’s supposed vindictiveness, fabrications, manipulations, instability and so on. (p. 26)[8]

Merrilyn McDonald, M.S.W. (1998), a family preservation therapist and guardian ad litem, notes:

Many times when a mother believes and defends her children, she is accused of being insane by the offender’s defense team. It seems easier to believe that a mother is insane than that a clean-cut, handsome man would sexually offend his children. The mother may present to the court as anxious, stressed and upset about the situation, which in some minds seems to support the idea of her insanity.

Anyone who supports the mother or child is similarly vilified and psychiatricly labeled. For example, Gardner notes that the mother will often enlist help from a female therapist who may “join in with the mother’s paranoid delusional system” (Gardner 1992a, p. 147).

The bias inherent in theories such as PAS has influenced how courts view and treat women during custody disputes. Penfold (1997, p. 18) notes: “beliefs about sick, vindictive mothers who are projecting problems from their own childhood onto innocent fathers, continue to influence court decisions and service delivery.” Her concerns were supported in a report of the Law Society of B.C. Gender Bias Committee (1992) which notes that, although statistics have found false accusations during child custody disputes to be rare, lawyers tend to advise their female clients not to raise accusations of sexual abuse because they will jeopardize their chances of receiving custody.

Summary

Gardner ‘s theories are seriously flawed through their reliance on faulty reasoning and erroneous assumptions. Contrary to Gardner’s assumptions, accusations of child sexual abuse are relatively rare during custody disputes and are no more likely to be false than those raised in other circumstances. Gardner also misleads his readers by suggesting that abusive men and nonalienating women act in an oversimplified and easily recognizable fashion. If the couple does not adhere to Gardner ‘s assumptions of how a guilty man or a nonalienating woman should behave, then Gardner suggests that the abuse or neglect allegation is false. PAS theory has drawn widespread criticism for its failure to take into account the many alternative causes for the family dynamics observed in divorcing families. Gardner ‘s theories have also been criticized for their unwavering bias in favor of accused child molesters and against women and children.

Lack of Scientific Basis for PAS Theory

In order to limit the admissibility of “junk science” in our nation’s courtrooms, courts have sought means of insuring the reliability and validity of scientific evidence. In 1993, the Supreme Court ruled that judges are obligated to scrutinize scientific evidence. In Daubert v. Merrell Dow Pharmaceuticals (113 S. Ct. 2786, 1993), the court held that an expert with sufficient credentials and something relevant to say was an insufficient standard. The Federal Rules of Evidence require judges to be “gatekeepers” who “must ensure that any and all scientific testimony or evidence admitted is not only relevant, but reliable.”

The Court provided a four-step process that courts should use in determining the scientific basis of expert testimony:

1. Is the theory or technique at issue testable, and has it been tested?
2. Has the theory or technique been subjected to peer review and publication?
3. In the case of scientific techniques, what is the known or potential error rate, and are there standards controlling the technique’s operation?
4. Does the technique enjoy general acceptance within the scientific community?

This section examines PAS in relation to each of the criteria delineated by the judicial system. Because Gardner ‘s criteria for differentiating true from false accusations (the SALS and the Protocols ) are derived from the same theoretical framework as PAS, they are prone to similar errors and criticisms and are included in this section.

Is PAS Scientific?

PAS is considered to be a “nondiagnostic” syndrome. A syndrome, as defined by Merriam Webster’s Collegiate Dictionary (1993), is “a group of signs and symptoms that occur together and characterize a particular abnormality.” Nondiagnostic syndromes refer to syndromes whose symptoms are not directly related to the relevant diagnoses (Faller, 1998; Myers, 1993). For instance, Myers (1993, p. 1455), notes that PAS syndrome is not a diagnostic tool and provides “no insight into the cause of . `parental alienation.'” Since it is nondiagnostic, Myers suggests that PAS “should not be admissible to prove that a person’s symptoms result from a particular cause.”

Another major criticism of PAS theory and the various instruments that Gardner has developed to determine the likelihood of abuse, is their lack of a scientific foundation. Although there is currently a great deal of research on child sexual abuse, Gardner ignores the literature–relying instead on his own assumptions, opinions and beliefs. For example, in his book Sex Abuse Hysteria: Salem Witch Trials Revisited , Gardner (1991, p. 2) states: “The term scientific proof [italics in original] is not applicable to most of the issues discussed here.”

Actually, Gardner ‘s dogmatic assertion that PAS exists is the only proof Gardner ‘s offers that such a syndrome is valid. For instance, on his website Gardner (July 8, 1999) states:

The PAS exists! Any lawyer involved in child-custody disputes will attest to that fact. Mental health and legal professionals involved in such disputes are observing it. They may not wish to recognize it. They may refer to it by another name (like “parental alienation”). 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.[9]

In addition to being nonscientific, Gardner ‘s argument is simplistic and misleading. PAS theory not only labels a phenomenon, it purports to explain how it came about. However, the fact that a theory appears to accurately describe a phenomenon does not mean that it explains the phenomena correctly. For example, the fact that the moon appears white and has craters, in no way proves that it is made of Swiss cheese. And the fact that a tree exists does not explain how the tree came to grow. Accordingly, the fact that a child is alienated from a parent during an acrimonious custody dispute does not prove that the other parent brainwashed the child. Cause and effect relationships can only be determined through carefully designed and performed scientific studies-which, in the case of PAS, have never been done.

Scientific Validity

In order to qualify as scientific knowledge, expert testimony must be based on conclusions derived from a scientific method. According to the Daubert ruling, in any case involving scientific evidence “evidentiary reliability will be based upon scientific validity.” For a theory or instrument to be considered valid, it must be shown to actually measure the phenomenon in question. However, even Gardner has admitted that his work lacks scientific validity. Gardner (September 6, 1993) states that PAS “is an initial offering and cannot have pre-existing scientific validity.”

One means of testing scientific validity is by comparing test results with known cases. For example, a researcher who develops a scale must test the instrument to ensure that it makes accurate determinations. As noted previously, Gardner has never tested any of his instruments. However, psychologist Martha L. Deed tested the SALS to see if it could differentiate between sex abuse cases that have been disproven and those that have been proven through medical findings or confession. She found that the SALS generally produced inaccurate assessments (Sherman, 1993, p. 46).

Douglas Darnall (1998), a forensic psychologist and author of Divorce Casualties: Protecting your Children from Parental Alienation, found similar problems when he attempted to validate a scale he developed based on Gardner ‘s PAS theory.

The Scale was written to identify the extent a parent behaves or harbors attitudes that cause or reinforces alienation between their child and the other parent. I started to validate the PAS Scale against the MMPI (Personality test). I initially found that high scores on my PAS Scale correlated with high scores on the MMPI’s 4 and 6 scale. This suggests that parents with high PAS scores were angry, suspicious, and pretty much fit the profile you would expect from an alienating parent. Then I noticed a problem. I learned that many parents with high PAS scores and elevated 4 and 6 scales also had other problems. Many of these parents were in fact abused in their relationship with the other parent or the children were abused. In effect, the high PAS score was significant but could not always discriminate between alienating behavior and actual victimization. So at this point, the high PAS score tells us that there is something wrong and the parent may be causing alienation, but you can not make any conclusions or ascribe any motivations, sinister or otherwise, about why the parent is behaving in that manner .. The point I am making here is that evaluations are complex and much needs to be researched.

Reliability

The second important component of testing any new instrument is evaluating its reliability. Reliability refers to the stability and repeatability of the data collection instrument. A reliable instrument obtains consistent results when the same case is examined by different evaluators. Faller (1998) notes that because of the possibility of multiple interpretations of its symptoms, the PAS is very vulnerable to problems of interrater reliability.

Jon Conte, associate professor at the University of Washington and editor of the Journal of Interpersonal Violence , asserts that the SALS is “probably the most unscientific piece of garbage I’ve seen in the field in all my time . To base social policy on something as flimsy as this is exceeding dangerous” (Moss, December 1, 1988). Conte coauthored an article with Luci Berliner which cites numerous problems with the SALS.

There are no studies which have determined if the Scale can be coded reliably. Many of the criteria are poorly defined. There have been no scientific tests of the ability of the SAL to discriminate among cases, and there is no evidence that the numerical scores have any real meaning. Indeed, to our knowledge, the entire scale and Parental Alienation Syndrome on which it is based have never been subjected to any kind of peer review or empirical test. In sum, there is no demonstrated ability of this scale to make valid determinations based on the identified criteria. (Berliner & Conte, 1993, p. 114)

Even Terence Campbell, a psychologist and member of the scientific advisory board of the False Memory Syndrome Foundation who is generally supportive of Gardner ‘s theories, is critical of the SALS in this regard. Campbell (1997, p. 15) notes that the SALS criteria are “vague and ill-defined,” and as a result they invite a wide range of subjective opinion. Campbell states:

There has never been any empirical evidence published in a peer-reviewed journal demonstrating that mental health professionals apply the SAL scale in a consistent and reliable manner .. A careful review of the SAL scale clearly demonstrates that, as in the case of other indicator lists, Gardner ‘s criteria cannot support expert testimony in legal proceedings.

Have Gardner ‘s Theories Been Subjected to Peer Review?

Another means for a theory to be evaluated is through peer review. Peer review refers to the process used by scientific journals to choose articles for publication. An article that is submitted for peer review is reviewed anonymously by professionals with expertise in the subject matter being written about. This process helps insure that the theory is based on sound scientific principles. Gardner has generally circumvented peer review of his theories by self-publishing his books through his own private publishing company, Creative Therapeutics, and by submitting his articles to legal journals or non-peer reviewed psychological journals.

At his website, Gardner (http://rgardner.com/refs/PAS_PeerReviewArticles.html, accessed August 6, 1999) refutes charges that his theories have not been peer-reviewed by listing eight publications about PAS which he claims were published in “peer reviewed journals.” Upon inspection, two of publications he lists were not published in journals, but are chapters in edited books. Authors are usually invited to publish a chapter in a book. Thus, chapters are not submitted anonymously and are usually not peer reviewed. Two other articles were published in the Academy Forum, a quarterly news-magazine published by the American Academy of Psychoanalysis (AAP). The Academy Forum is not a journal, and according to the AAP (of which Gardner is a member), the Forum is not peer reviewed; rather it “provides an opportunity for members to present their views on issues pertaining to practice, social conflict and change, literary criticism, the arts, book reviews and the state of the world” (Merlino, 1998).[10] The official peer-reviewed journal of the Academy is the Journal of the American Academy of Psychoanalysis, in which Gardner has not published.

Two articles were published in legal journals: New Jersey Family Lawyer and Court Review . It should be noted that Gardner is a psychiatrist who has developed a psychological theory. Legal journals focus on legal theories, and are reviewed by attorneys. The point of peer review is that the work be evaluated by experts within the appropriate field. In this case, meaningful publication and review of Gardner ‘s work would be by mental health professionals, not defense attorneys.

The two remaining articles were recently published in The American Journal of Family Therapy . This actually is a peer-reviewed journal. However, Gardner ‘s articles are based totally on his own opinions and he does not cite any relevant research to support them. In fact, the majority of the works he cites are his own. It is interesting to note that even Gardner (1992a, p. 59) has stated, “Empirical testing or studies and observations by others must occur rather than be limited to one practitioner’s clinical observation of his own private practice patients.”[11]

It should be noted that Gardner ‘s writings have been reviewed in a number of peer-reviewed psychological and psychiatric journals. His theories have almost uniformly been criticized and rejected by other mental health practitioners (e.g., Amaya-Jackson & Everson, 1996; American Psychological Association, 1996; Berliner & Conte, 1993; Campbell, 1997; Faller, 1998; Rotgers & Barrett, 1996).

What is the Known or Potential Error Rate?

The diagnosis of PAS relies heavily on subjective clinical judgments rather than objective, validated criteria. Although it has been almost 15 years since Gardner first proposed PAS theory, he has never performed any tests to confirm PAS or any of the various instruments he developed based on PAS theory. However, many of the assumptions upon which PAS theory is based have been tested by various researchers and been found to be erroneous. Because Gardner ‘s methods of determining abuse have been found to be seriously flawed, PAS provides little probative value to courts in making decisions about the presence or absence of sexual abuse. Moreover, because abuse is notoriously difficult to completely rule out, and since Gardner (1999, p. 97) admits that PAS has no applicability to cases involving actual abuse, it seems clear that PAS theory should not be allowed in any case in which abuse is a possibility.

Forensic psychologist Frederick Rotgers and attorney Deirdre Barrett (1996) note that “if the theoretical explanation underlying the data is faulty, the data may be presented in such a fashion that misleads the trier of fact.” Based on the many conceptual problems and faulty assumptions underlying PAS, it is reasonable to conclude that the application of PAS theory to divorcing families will result in erroneous determinations. This conclusion is supported by research done by Deed (Sherman, 1993, p. 46) and Darnall (1998) who found that the application of Gardner ‘s criteria for both abuse and PAS often produced inaccurate results.

Lack of General Acceptance in the Scientific Community

PAS is not listed in the American Psychiatric Association’s Diagnostic and Statistical Manual (DSM) as a psychiatric disorder and is not recognized as a valid medical syndrome by the American Medical Association, or the American Psychological Association. However, rather than concede that the PAS does not meet the minimum suggested guidelines for inclusion in the DSM-IV.[12] Gardner blames its lack of recognition on “politics.” The following statement found on Gardner ‘s website is interesting because Gardner admits that not only is PAS not accepted by the scientific community, it is in fact the object of “scorn, rejection and derision.” Gardner (1998) states:

The PAS has been dragged into the political-sexual arena, and those who would support its inclusion in DSM-IV are likely to find themselves embroiled in vicious controversy and the object of scorn, rejection, and derision. The easier path, then, is to avoid involving oneself in such inflammatory conflicts, even if it means omitting from DSM one of the more common childhood disorders.

Several legal scholars examined the PAS and determined that PAS does not meet any of the courts’ minimum threshold requirements to qualify as scientific. Poliacoff, Greene, and Smith, (1999) note: “In the case of PAS Gardner has based his theory entirely upon the observation of his own patients. It is for the most part self-published which circumvents peer review, and has not attracted wide acceptance in the scientific community.”

Attorney Cheri Wood (1994) suggests that although Gardner ‘s self-published theories do not have any empirical grounding, they have been given a “dangerous and undeserved aura of reliability and trustworthiness” in the courtroom. Wood concludes that PAS should not be admissible in court for the following reasons: (1) because it has not gained acceptance among experts in the field, (2) because of difficulties in determining causation, and (3) because it endangers children. Wood (1994, p. 1414-5) asserts that: “All psychological evidence upon which a child’s safety will turn must be subjected to meaningful peer review, publication, or empirical testing.”

Even among psychologists, PAS has been cited an example of bad science that has been presented to the courts as credible forensic evidence. In an article published in Professional Psychology: Research and Practice , Rotgers and Barrett (1996) cite PAS theory as a prime example of a nonscientific theory that engages in “reverse logic.” This problem was also noted by Benjamin D. Garber, a clinical child psychologist, who points out that the presumption that a child’s distress during his or her parents’ divorce is the result of alienation is often a confusion of cause and effect. Garber (1996, p. 51) notes “both the physical and social sciences demonstrate that a cause cannot necessarily be inferred from an effect.”[13]

The American Psychological Association Presidential Task Force on Violence And The Family (1996) states that “no data” exist to support PAS. An article published in American Psychological Association’s APA Monitor quotes Robert Geffner, Ph.D., a San Diego psychologist and expert on family violence issues: “While psychologists agree that some parents resort to such behavior, parental alienation syndrome is not a valid diagnosis and shouldn’t be admitted into child custody cases” (Sleek, 1998).

Margaret Hagen, a Boston University professor of psychology and author of Whores of the Court , considers PAS to be a prime example of a bogus psychological theory that is infecting the nation’s legal system. Hagan states: “You don’t throw in a phony junk-science syndrome and base a custody agreement on that. The court needs to toss out this stuff and deal with each case on an individual basis” (Goldsmith, 1999).

The Need for Reform

While psychological expert testimony is often necessary, the clinical judgments of mental health experts are often seriously flawed. Although a psychologist’s or psychiatrist’s testimony may be riddled with errors, their technical vocabularies can create an impressive appearance of expertise. Bolocofsky (1989) suggests that the over-reliance of mental health professionals on questionable sources of data and subjective clinical judgments points to the need for some form of regulation of child custody evaluators. Bolocofsky suggests that “at the very least” professionals should be required to identify the sources for their opinions and the limitations of their data. Rotgers and Barrett (1996, p. 472) agree. They suggest that psychological experts who base expert opinions on theories and syndromes (like PAS) that have not been validated scientifically need to make that fact clear to the court and to explain the resultant limitations of their opinions. They state: “Failure to do so could result in an abuse of the expert role and a distortion of the fact-finding process of the case in question.”

One solution that has been proposed is make impartial scientists available to advise judges. For example, the American Association for the Advancement of Science (AAAS) has formulated The Court Appointed Scientific Experts project. Under the AAAS plan, impartial scientists who are removed from the adversarial process would help judges make decisions regarding the admissibility of scientific evidence (Faigman, 1999).

Conclusions

In spite of its many shortcomings, many courts have accepted PAS because it apparently appears to explain a well-recognized phenomenon within custody battles – the often acrimonious fight between parents for their child’s affection. However, Daubert demands that scientists conduct competent science before becoming paid experts. Gardner ‘s PAS theory and his various scales to differentiate true and false claims of child sexual abuse are not informed by science and have been discredited by his peers. Rather than subjecting his theories to scientific review, most of Gardner ‘s writings are published through his own press or in nonscientific journals. Because Gardner ‘s theories are based on his clinical observations and not on scientific data, they must be understood in the context of his atypical views concerning pedophilia and child sexual abuse.

Gardner ‘s theories are based on his assumption that sex between a child and an adult is not inherently harmful, and his belief that there is an epidemic of false sexual abuse allegations being made by vengeful wives during custody disputes. Gardner maintains these beliefs in spite of a wealth of clinical and experimental data which prove otherwise. This is not to imply that such allegations are always accurate, or that parents do not attempt to manipulate their children during adversarial custody litigation. However, Gardner ‘s theories are not sufficiently scientific to be able to make cause and effect determinations, are biased against women and children, and are flawed by their failure to take into account alternative explanations for the behavior of the parties involved.

Frustration over bitter custody battles should not tempt the legal system to blindly accept unproven theories such as PAS. Reliance on such simplified approaches to the complex problem of alleged abuse in the context of child custody disputes is likely to result in misdiagnosis and a failure to protect children. High conflict divorces take an emotional toll on children, and this toll should not be exacerbated through the use of “junk science” which may wrongly deny children a relationship with the parent who has heretofore been their primary caretaker. In the end, all psychological evidence upon which a child’s safety will turn should represent the best that science has to offer, not one man’s unsupported opinions and assumptions.

ENDNOTES

1.    It is interesting that Gardner advocates severing the relationship between a child and a mother who he considers to be emotionally abusive, yet he stresses maintaining and building the relationship whenever possible with fathers who have been found to have sexually abused their child. For example, in reference to sexually abusive fathers, Gardner (1992b, p. 572) states: “There is no such thing as a parent who is perfect .. The sexual exploitation has to be put on the negative list, but positives as well must be appreciated [by the child].”

2.    See: Dallam, S.J. (1998). Dr. Richard Gardner: A review of his theories and opinions on atypical sexuality, pedophilia, and treatment issues. Treating Abuse Today, 8(1),15-23.

3.   Ann Haralambie, an attorney and past president of the National Association of Counsel for Children, faults Gardner for misapplying a legal principle-that it is better to allow 100 guilty men to go free than to wrongly convict one innocent man-to child custody cases involving sexual abuse. Haralambie points out, “That principle comes from the criminal justice arena and has no legal application to a custody dispute” (Moss, December 1988). Put in proper context, the principle could be stated: it is better that 100 molested children go unprotected than to have one father’s relationship with his child inappropriately interfered with.

4.   Faller (1998, pp. 103-4) points out a major inconsistency in Gardner ‘s reasoning concerning child abuse allegations. Although Gardner says that he believes that incest is quite common and that allegations that arise in the context of an intrafamilial situation have a high likelihood of being valid, he considers the vast majority of abuse allegations that arise during custody disputes to be false. Faller notes: ” Gardner never states directly why he is so convinced. Nor, apparently, does he see a contradiction between his position on incest in intact families and incest in divorced or divorcing families. He evidently does not consider that a likely outcome of the discovery of incest is a decision by the mother to divorce the offending father.”

5.    This criteria appears to provide assurance that any man who can afford Gardner ‘s fee, which is purported to be $500 an hour (Goldsmith, 1998), will not be found to be abusive.

6.    Although Gardner views himself as impartial, in a 1991 case, Judge Jacqueline Silberman stated: “[F]or the record, I have never heard a worse hired gun in my life than Dr. Gardner ” (Carpenter & Kopas, 1998).

7.    Critics note that Gardner almost always sides with a man against his wife. Dr. Joyce Wallace, a Manhattan physician noted for her pioneering AIDS research, claimed that Gardner represented himself to her as a conjoint therapist when, in fact, he had been hired by her husband to help him get custody of their children (Sherman, 1993, p. 46). Dr. Wallace sued Gardner . Gardner denied misleading Dr. Wallace, but paid her a $25,000 settlement in 1988. The court dismissed her husband’s custody suit.

8.    More information on the inappropriate psychiatric labeling of mothers can be found in the following book: Allison, D.B., & Roberts, M.S. (1998). Disordered mother or disordered diagnosis? Munchausen by proxy syndrome. Analytic Press.

9.    For a similar statement, see Gardner (September 18, 1996).

10.  This information can be found at the AAP website: http:// aapsa.org.

11.  Gardner also publishes his articles in a little known journal titled Issues in Child Abuse Accusations, which he claims is peer-reviewed.It should be noted that the journal is printed out of the office of Ralph Underwager and Hollida Wakefield. Underwager and Wakefield founded and edit the journal and write most of the articles. They claim the journal is peer reviewed though there is no indication of a such a process. In fact, in the first issue of the journal Wakefield and Underwager (1989) stated: “This journal has a point of view, ours.” Underwager gained considerable notoriety some years ago when statements he made in an interview for the Dutch journal for pedophiles called Paidika: The Journal of Paedophilia . In the interview, Underwager stated: “Paedophiles need to become more positive and make the claim that paedophilia is an acceptable expression of God’s will for love and unity among human beings.” Underwager and Wakefield co-founded the False Memory Syndrome Foundation which advocates for parents accused of abusing their children. Most of the articles printed in Issues in Child Abuse Accusations are supportive of people accused of molesting children. Gardner ‘s contributions are no exception. (For more information on Underwager and Wakefield , see: Dallam, S.J. (1997). Unsilent witness: Ralph Underwager and the FMSF. Treating Abuse Today , 7(1), 31-9. Available online at http://www.idealist.com/tat/).

12.  Blashfield, R. K., Sprock, J., & Fuller, A.K. (1990). Suggested guidelines for including or excluding categories in the DSM-IV. Comprehensive Psychiatry, 31, 15-19.

13.  The Florida District Court of Appeal ( In the Interest of T.M.W ., 553 So. 2d 260, 262, Fla. Dist. Ct. App., 1989) suggested that holding one parent more responsible than the other for a child’s alienation would require proving that the alleged alienating conduct “is so significant to outweigh the combined effect of all other causes.” Since causation cannot be reliably sorted out, the Florida court held that PAS evidence, like the once popular tort of spousal alienation of affection, should not be admitted in court.