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Journal of Child Custody
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Recommended treatments for “parental alienation
syndrome” (PAS) may cause children foreseeable
and lasting psychological harm
Stephanie Dallam & Joyanna L. Silberg
To cite this article: Stephanie Dallam & Joyanna L. Silberg (2016) Recommended
treatments for “parental alienation syndrome” (PAS) may cause children foreseeable
and lasting psychological harm, Journal of Child Custody, 13:2-3, 134-143, DOI:
To link to this article: http://dx.doi.org/10.1080/15379418.2016.1219974
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JOURNAL OF CHILD CUSTODY
2016, VOL. 13, NOS. 2–3, 134–143
Recommended treatments for “parental alienation
syndrome” (PAS) may cause children foreseeable
and lasting psychological harm
Stephanie Dallama and Joyanna L. Silberga,b
aLeadership Council on Child Abuse and Interpersonal Violence, Baltimore, Maryland, USA; bSheppard
Pratt Health System, Baltimore, Maryland, USA
The coercive and punitive “therapies” recommended for
children diagnosed with parental alienation constitute an
ethical minefield and are especially inappropriate when used
on children who have already been traumatized. Forced
reunification against a child’s will and without taking into
consideration the child’s point of view and emotional well-
being, can be expected to reinforce a sense of helplessness and
powerlessness in an already vulnerable child. Such “treatment”
can be expected to do more harm than good, and rather than
helping their well-being, could cause lasting psychological
harm, particularly when imposed upon children who claim the
parent they are being forced to reunify with is abusive.
Child abuse; parental
We are in agreement with the broad critiques of parental alienation theory as
offered by O’Donohue, Benuto, and Bennett (2016) and Clemente and
Padilla-Racero (2016) in this issue, and many of the researchers that they cite.
“Parental alienation syndrome” (PAS) criteria are vague and subjective,
nondiagnostic, and inconsistent with good child-centered evaluation. As a
result, PAS proponents frequently draw conclusions based on pure specu-
lation, correlation without demonstrated causation, and inference without
any foundation other than their own beliefs about how children should think
and behave during a stressful divorce. Current proponents of parental
alienation, including Bernet (2008) and Warshak (2015), have attempted to
circumvent widespread condemnation of PAS by replacing it with parental
alienation disorder (PAD) or simply parental alienation. While they have
attempted to imbue their viewpoints with the mantle of science, the criteria
used to determine alienation are the same ones offered by Gardner and thus
the same criticisms of Gardner’s theory of PAS are applicable as noted in the
Commentaries in this issue noted above as well as by others (e.g., Houchin,
Ranseen, Hash, & Bartnicki, 2012; Meier, 2013; Saini, Johnston, Fidler, & Bala,
2016). In rejecting PAD for inclusion in the latest revision of the Diagnostic
CONTACT Stephanie Dallam firstname.lastname@example.org Leadership Council on Child Abuse and Interpersonal
Violence, P.O. Box 6815, 6501 N. Charles St., Baltimore, MD 21204.
© 2016 Taylor & Francis
and Statistical Manual of Mental Disorders (DSM), Dr. Darrel Regier, vice
chair of the DSM task force, stated, “It’s a relationship problem—parent–child
or parent–parent. Relationship problems per se are not mental disorders.” The
Board of Trustees would not even consider putting it in a section for disorders
needing further research (Thomas & Richardson, 2015, p. 33). Our view is
that the ongoing harm to children that this faulty concept has engendered
is significant. In this Comment, we examine some of the diagnostic and treat-
ment implications derived from PAS that can harm children and families.
The potential for PAS diagnoses to harm children is not surprising given the
concept’s origin. As noted in the Commentaries, PAS was invented by Richard
Gardner based on his clinical impressions of cases he believed involved false
allegations of child sexual abuse (Gardner, 1985). At the time, Gardner was
a frequent expert witness, most often on behalf of fathers accused of molesting
their children (Sherman, 1993). Thus, PAS was first described to counter sex-
ual abuse allegations in custody litigation. Without citing any evidence,
Gardner (1987) claimed that PAS is responsible for most accusations of child
sexual abuse that are raised during custody disputes, and that in his experience
“in custody litigation … the vast majority of children who profess sexual abuse
are fabricators” (p. 274). As a result, PAS has frequently been introduced into
custody cases by parents whose child has rejected them in order to discredit
allegations of family violence or abuse (Bruch, 2001). Actual research, on
the other hand, has consistently shown that sexual abuse allegations are not
common during custody litigation and when thoroughly investigated, are
often no more likely to be false than allegations raised at other points in time
(see Dallam & Silberg, 2006 for a review). Yet, even when abuse claims were
valid, Gardner appeared to believe that PAS was more detrimental than sexu-
ally abusing a child. For example, Gardner (2000) considered PAS to be a form
of emotional abuse that can lead to lifelong psychiatric disturbance in the
child. Conversely, Gardner claimed that the determinant as to whether the sex-
ual abuse will be traumatic for a child “is the social attitude toward these
encounters” (1992a, pp. 670–671) and that special care should be taken by
the therapist to not alienate the child from the molesting parent (p. 537).
Gardner’s theory of parental alienation was based on the assumption that if
a child rejects their parent (usually the father) after allegations of abuse, the
other parent (i.e., the mother) must have brainwashed the child. As Gardner
(1992b) stated, “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” (p. 75). Thus, problems in
the child’s relationship with the father were simply blamed on brainwashing
by the mother. The recommended solution to remedy PAS involves coercive
and punitive treatments for both the mother and the child along with switch-
ing custody to the rejected parent as noted by Clemente and Padilla-Racero
(2016) in this issue. Although Gardner (2001) said that children may then
JOURNAL OF CHILD CUSTODY 135
add their own contributions to the vilification of a parent, there is minimal
indication in Gardner’s perspective that children can react to a parent based
on their own experiences, feelings, and beliefs. Thus, the mental life of the
child who is being diagnosed with PAS is largely ignored in Gardner’s
Gardner’s theory of PAS has been difficult to overcome because he relied
on popular gender and cultural myths (see Dallam & Silberg, 2006 for a
review) and offered courts a simple explanation for very complex cases.
One judge wrote that when she first read Gardner’s (1987) book The Parental
Alienation Syndrome and the Differentiation Between Fabricated and Genuine
Child Sex Abuse, she believed that “Dr. Gardner had just handed me the key to
the mysteries of all my high-conflict family law custody cases … the magic of
the theory was intoxicating” (Slabach, 2014, p. 8). One reason the theory
seemed so comprehensible was that the definition of PAS includes its
hypothesized etiological agents (i.e., a manipulative/alienating parent and a
receptive child) (Kelly & Johnston, 2001). This renders Gardner’s theory of
PAS unfalsifiable because it is tautological (i.e., true by definition). The child’s
denial that such brainwashing has taken place and the mother’s attempts to
obtain professional assistance in diagnosing, treating, and protecting the child,
are then used by Gardner and proponents of his views as evidence of alien-
ation. Thus, Gardner’s theory works backward using circular reasoning to
assume causation from an observation. As a result, Rotgers and Barrett
(1996) cite PAS theory as a prime example of a nonscientific theory that
engages in reverse logic.
The rejected parent’s role in contact refusal
As a theory, PAS is black and white with minimal attention given to family
dynamics or child development. The alienating parent was painted by
Gardner as pathological and completely to blame for the child’s position.
The rejected parent in Gardner’s theory was totally blameless and the “true
victim” (Gardner, 2002, p. 26). In actuality, when a child rejects a parent there
is a wide range of possible explanations including normal developmental
conflicts with a parent, separation anxiety with the preferred parent, abuse,
or neglect, etc. (e.g., Faller, 1998; Garber, 1996). Moreover, research on the
topic has found that rejected parents often have contributed to their situation.
Huff (2015) surveyed 292 young adults (18–35 years old) who were between
8 and 17 at the time their parents separated. He found that that violence and a
perceived lack of warmth were significant predictors of contact refusal with a
parent. The largest effect size for predicting contact refusal was for the degree
to which participants reported being aligned with the other parent. At the
same time, co-parental conflict and parents’ alienating behaviors had little
to no direct contribution to contact refusal after controlling for the other
136 S. DALLAM AND J. L. SILBERG
variables in the model. Huff’s study is of particular importance since alienat-
ing behaviors are the primary variable that alienation proponents claim causes
contact refusal. His study found that participants were not influenced to reject
a parent due to manipulation by the other parent; instead, they tended to align
with the parent who exhibited the most caring behavior toward them.
These findings are supported by prior studies looking at children’s rejection
of a parent after divorce. Lampel (1996) studied 24 consecutively referred chil-
dren of parents in custody litigation. She found that the rejected parent’s
demonstration of empathy was a better predictor of a child’s rejection than
manipulation by the preferred parent. She concluded, “The complex family
dynamics suggested by these studies are that a closed parent system, in which
both parents are defensive and remain in conflict, led the child to align with
the more problem solving, capable, and outgoing of the two parents” (p. 239).
Johnston, Walters, and Olesen (2005) found that substantiated accounts of
abuse significantly predicted parental rejection when controlling for a variety
of other factors, including alienating behaviors by the other parent.
Acceptance of PAS can result in failure to adequately investigate
reports of abuse
One of the biggest pitfalls of having children evaluated by someone trained
in parental alienation theory is that the assumption of manipulation by the
preferred parent means that the rejected parent is deemed by evaluators to
be the only source of “credible” information; the preferred parent and child
are not viewed as credible and thus their concerns are often ignored. This
parent and the child often quickly realize that the evaluator does not believe
them, is biased, and has their mind made up. This can lead to them shutting
down and not providing information, or even exaggerating actual abuse to be
more extreme in an attempt to get the evaluator to pay attention.
Although proponents of parental alienation agree that substantiated abuse
rules out a diagnosis of PAS, many custody evaluators appear predisposed to
attribute abuse allegations to vindictiveness, rather than exploring whether
there is a factual basis for the child’s disclosure or the protective parent’s con-
cerns (e.g., Saunders, Faller, & Tolman, 2011). In addition, as Johnston,
Roseby, and Kuehnle (2009) pointed out, parental violence, abuse, and neglect
range on a continuum from blatant acts to more subtle forms of emotional
abuse, neglect, and a lack of empathy and concern for the child that may
not be acknowledged, difficult to document, and unreported or dismissed
by authorities. Even when abuse is formally investigated, it is frequently not
substantiated as allegations of interpersonal violence can be very difficult to
independently confirm, especially if the law enforcement or child protective
services personnel also believe in the myth of PAS and, therefore, do not
conduct their normal comprehensive investigations.
JOURNAL OF CHILD CUSTODY 137
Parental alienation proponents, on the other hand, often assert that they
can easily determine whether abuse has occurred, often with no formal evalu-
ation of the child or family (e.g., Childress, 2015). Once they make their deter-
mination, custody evaluators schooled in PAS theory were instructed by
Gardner to ignore and aggressively contradict any abuse disclosures by a child
they believe to be alienated. For example, Gardner (1999) wrote, “The court’s
therapist must have a thick skin and be able to tolerate the shrieks and claims
of impending maltreatment that PAS children often profess.… To take the
allegations of maltreatment seriously, is a terrible disservice to PAS children”
(pp. 201–202). Similarly, Warshak (2015) noted that children can be very
convincing in their accounts of poor treatment at the hands of the rejected
parent and, as a result, “[n]aive therapists who lack specialized knowledge
and experience with alienation cases may inadvertently reinforce the
children’s alienation by accepting their patients’ representations as accurate”
(p. 246). Gardner (1999) even directed therapists to actively counter
allegations of abuse if they believed them to be false. He stated, “[I]t is thera-
peutic to say, ‘That didn’t happen! So let’s go on and talk about real things,
like your next visit with your father’” (p. 202).
We find this position to be inherently dangerous, not only because it is dis-
respectful to children, but also because of the very real possibility of abused
children being misdiagnosed as alienated and placed with their abuser. The
ability for PAS and its offshoots to harm children was recognized by the
National Council of Juvenile and Family Court Judges, a leading judicial body,
in its published guidelines noting that PAS may divert attention away from
the behaviors of an abusive parent by assuming that child’s attitudes toward
that parent have no basis in reality (Dalton, Drozd, & Wong, 2006).
Because of the difficulty in substantiating allegations of interpersonal
violence in custody cases, the American Professional Society on the Abuse
of Children (2013) recommends a comprehensive family evaluation by mental
health professionals with expertise in interpersonal violence. Evaluators
should conduct more than a single interview with children, rely upon multiple
methods of data collection and, whenever feasible, a team approach should be
used to mitigate individual bias. Even with such a careful investigation,
finding insufficient evidence for a finding of abuse does not mean that
“brainwashing” is the most likely alternative. It is very difficult to substantiate
abuse particularly in young children and, as noted previously, parental
rejection has many causes.
Experimental and punitive treatments for PAS
Both PAS and PAD are built on the assumption the relationship of an
alienated child with the rejected parent will be irreparably damaged, unless
drastic measures (custody transfer, isolation from the loved parent, and
138 S. DALLAM AND J. L. SILBERG
deprogramming) are taken. These theories further assume that the child will
suffer permanent psychological harm if they are not forced to see the rejected
parent. Consequently, the recommendations of PAS advocates can endanger
children by separating them from the parent with whom they are most
bonded and attempting to force the child to accept the rejected, and possibly
Gardner (2001) claimed that children with PAS require an authoritarian
and confrontational approach. As a result, treatment of children who diag-
nosed with parental alienation involves incarceration, threats, and/or special
reunification “camps” where children are held against their will to be indoc-
trinated into rejecting the influence of the parent with whom the child is most
bonded (see Gardner, 1999, 2000, 2001). Current treatments for alienation
have not been empirically studied for efficacy and Johnston and Kelly
(2004) described Gardner’s prescriptions for treating PAS “a license for
tyranny” (p. 85).
Recently a number of reunification “camps” to treat PAS have emerged (see
Slabach, 2014; Warshak, 2010b). The operators of reunification “camps” often
emphasize that these are not treatment programs but instead are “edu-
cational” in nature, thus avoiding scrutiny of regulating bodies (Houchin
et al., 2012). Houchin et al. noted that these “educational” programs are a bur-
geoning industry that are making some professionals and lay people quite
wealthy, but which have no empirical support other than the claims of those
who run the programs. Many of these programs are run out of hotel rooms.
Before agreeing to take the child, most of these “camps” require that the court
sign special orders to prevent the preferred parent and child from having any
contact (including phone, texts, e-mail or Facebook) for a period of at least
90 days. These no contact orders require that the rejected parent be given
sole legal custody, and that the preferred parent, along with the child’s other
family and friends, are not allowed to know where the child is being held.
The child’s cell phone is taken and all communications are restricted and
monitored. The child may be threatened that if they make any attempt to
contact their preferred parent, they both will be in trouble with the court, and
that the 90-day period of no contact will start over again (e.g., Warshak, 2014).
Isolating a child from everyone they are familiar with and attempting to
force them to adopt a different view of a parent, especially by strangers
who know little about the child’s actual experiences, can in and of itself be
traumatic. Warshak (2010b) who runs Family Bridges, a reunification
program for “alienated” children, wrote that that when children are court-
ordered into Family Bridges and told they can have no further contact with
their preferred parent, “It is not uncommon for children to react by scream-
ing, refusing to go, threatening to run away, sobbing hysterically, and, in one
case, hyperventilating” (p. 61). At the same time, Warshak (2010a) claimed,
“Despite their vehement protests, children and teens welcome the sense of
JOURNAL OF CHILD CUSTODY 139
protection and control that comes when adults exert appropriate authority to
keep children on the right track” (as cited by Warshak & Otis, 2010, p. 93)
However, no peer reviewed research to support such claims has been published.
Research refutes forced treatment for PAS
Research refutes the assumption that a child’s bond with a preferred parent
must be disrupted to safeguard the child’s relationship with the rejected
parent. Instead, researchers have found that if a child’s rejection of parent
is unwarranted, the child will usually reconcile with the parent on their
own without any intervention (e.g, Johnston & Goldman, 2010; Johnston
et al., 2009). Johnston et al. found that alignments with a preferred parent
are usually time-limited. However, they noted if these cases are mishandled
through attempting to force the child to change allegiances, they can contrib-
ute to the entrenched position in the child. Research by Johnston and Gold-
man found that adults who were forced into reunification with a rejected
parent when they were a child had strong negative views and feelings about
the experience. Based on their research, Johnston and Goldman suggested a
“strategy of voluntary supportive counseling and/or backing off and allowing
the youth to mature and time to heal the breach” (p. 113) instead of forcing
adolescents to participate in counseling. They concluded that teenagers who
feel empowered and have their autonomy respected are better able to distance
themselves from the parental and family conflicts and consequently more
likely to initiate meaningful contact with the rejected parent. Other writers
who have looked at the issue argue that enforced treatment and custody rever-
sal are counterproductive, in that they will only serve to reinforce the child’s
hatred for the rejected parent, and add stress to the already vulnerable child
(e.g., Jaffe, Ashbourne, & Mamo, 2010; Johnston et al., 2009).
Silberg, Dallam, and Samson (2013) documented the harm that can come
when children are court ordered into custody of abusive parents. They ana-
lyzed the court records of 27 custody cases in which courts initially placed
children in the custody of an allegedly abusive parent and later reversed itself
and protected the child. Silberg et al. reported that family courts were highly
suspicious of a mother’s motive for being concerned with abuse and custody
evaluators and guardian ad litems (GALs) frequently accused mothers of
alienating their children from fathers and coaching them to report abuse.
In the majority of the cases (59%), the alleged perpetrator was granted sole
custody. Some mothers were not allowed any contact with their children,
and several others were ordered not to speak to their children about abuse
or report any further concerns about abuse or risk losing any further contact.
The children spent an average of three years in the abusive parent’s custody
before the case was reversed. Court records showed evidence of the children’s
deteriorating mental and physical condition including anxiety, depression,
140 S. DALLAM AND J. L. SILBERG
dissociation, PTSD, self-harm, and suicidality. Thirty-three percent of the
children became suicidal, some repeatedly ran away, and others ended up
in psychiatric hospitals.
Hopefully, the tide is beginning to turn on this issue. The lack of empirical
support for PAS theory has been repeatedly documented, as has the potential
for harm when children are diagnosed and treated for this pseudoscientific
condition. In addition, the confinement of children, who have no mental
disorder and who have committed no wrong doing, away from parents and
friends in unfamiliar surroundings in order to force them to adopt a new
belief system would appear to violate these children’s basic civil rights
(Kleinman & Kaplan, 2016). As a result, in our view, diagnosing children with
PAS (or following the same principles without using the label) and
recommending coercive and untested treatments for child who refuse contact
constitute a form of professional malpractice.
In summary, parental alienation as defined by PAS advocates is a popular,
but faulty, concept which has been disproven by research and is not accepted
by any professional mental health organization. Coercive and punitive “thera-
pies” recommended for children diagnosed with parental alienation constitute
an ethical minefield and are especially inappropriate when used on children
who have already been traumatized. Forced reunification against a child’s will
and without taking into consideration the child’s point of view and emotional
well-being, can be expected to reinforce a sense of helplessness and powerless-
ness in an already vulnerable child. Such “treatment” can be expected to do
more harm than good, and rather than helping their well-being, could cause
lasting psychological harm, particularly when imposed upon children who
claim the parent they are being forced to reunify with is abusive.
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