Parental AlienationSyndrome or SymptombyReginald Hirsch

IntroductionIntroduction

►1. “ I know it when I see it.”1. “ I know it when I see it.”►2. What is it?2. What is it?►3.Let’s first examine the 3.Let’s first examine the

literatureliterature►4.Then let’s examine the legal 4.Then let’s examine the legal

issues issues ►5.The future of PAS5.The future of PAS

Historical BackgroundHistorical Background

►Anna Freud and WallersteinAnna Freud and Wallerstein► Dr. Richard A. GardnerDr. Richard A. Gardner► The Man and the MythsThe Man and the Myths► 1. 1985 coined the term “PAS”1. 1985 coined the term “PAS”► 2. Is he qualified? See Appendix 12. Is he qualified? See Appendix 1► 3. www.rgardner.com 3. www.rgardner.com ► 4. Daubert and Robinson issues4. Daubert and Robinson issues

What is PAS?What is PAS?

► The parental alienation syndrome (PAS) is a The parental alienation syndrome (PAS) is a childhood disorder that arises almost exclusively childhood disorder that arises almost exclusively in the context of child-custody disputes. Its in the context of child-custody disputes. Its primary manifestation is the child’s campaign of primary manifestation is the child’s campaign of denigration against a parent, a campaign that has denigration against a parent, a campaign that has no justification. It results from the combination of no justification. It results from the combination of a programming (brainwashing) parent’s a programming (brainwashing) parent’s indoctrinations and the child’s own contributions indoctrinations and the child’s own contributions to the vilification of the target parent. When true to the vilification of the target parent. When true parental abuse and/or neglect is present, the parental abuse and/or neglect is present, the child’’s animosity may be justified and so the child’’s animosity may be justified and so the parental alienation syndrome explanation for the parental alienation syndrome explanation for the child’s hostility is not applicable.child’s hostility is not applicable.

► See, The Parental Alienation SyndromeSee, The Parental Alienation Syndrome (Second (Second Edition), by Dr. Richard A. Gardner, 1998, Edition), by Dr. Richard A. Gardner, 1998, Creative Therapeutics, Inc., at xx.Creative Therapeutics, Inc., at xx.

SyndromeSyndrome

►The medical definition of “syndrome” The medical definition of “syndrome” is a cluster of symptoms, occurring is a cluster of symptoms, occurring together, that characterize a specific together, that characterize a specific disease. The term “syndrome” shares disease. The term “syndrome” shares many and varied symptoms. many and varied symptoms. Disorders as used in DSM-IV are Disorders as used in DSM-IV are clinically observable and have set clinically observable and have set criteria that are used in order to make criteria that are used in order to make the specific disorder diagnosisthe specific disorder diagnosis

Diagnosis of PASDiagnosis of PAS

► As Dr. Gardner states, “the PAS is characterized by a cluster of As Dr. Gardner states, “the PAS is characterized by a cluster of symptoms that usually appear together in the child, especially symptoms that usually appear together in the child, especially in the moderate and severe types. These include: in the moderate and severe types. These include:

► A campaign of denigrationA campaign of denigration► Weak, absurd, or frivolous rationalizations for the deprecationWeak, absurd, or frivolous rationalizations for the deprecation► Lack of ambivalenceLack of ambivalence► The “independent-thinker” phenomenonThe “independent-thinker” phenomenon► Reflexive support of the alienating parent in the parental Reflexive support of the alienating parent in the parental

conflictconflict► Absence of guilt over cruelty to and/or exploitation of the Absence of guilt over cruelty to and/or exploitation of the

alienated parentalienated parent► The presence of borrowed scenariosThe presence of borrowed scenarios► Spread of the animosity to the friends and/or extended family Spread of the animosity to the friends and/or extended family

of the alienated parentof the alienated parent

DIFFERENTIAL DIAGNOSIS OF THE THREE TYPES OF PAS

MILD MODERATE SEVERE

The Campaign of Denigration

Minimal Moderate Formidable

Weak, Frivolous, or Absurd

Rationalizations for the Deprecation

Minimal Moderate Multiple Absurd Rationalizations

Lack of Ambivalence Normal Ambivalence

No Ambivalence No Ambivalence

The Independent-Thinker Phenomenon

Usually Absent Present Present

Reflexive Support of the Alienation

Parent in the Parental Conflict

Minimal Present Present

Absence of Guilt Normal Guilt Minimal to no Guilt

No Guilt

Borrowed Scenarios

Minimal Present Present

Spread of the Animosity to the Extended Family

and Friends of the Alienated Parent

Minimal Present Formidable, or Visit not Possible

Transitional Difficulties at the Time of Visitation

Usually Absent Moderate Formidable, or Visit not Possible

MILD MODERATE SEVERE

Behavior During

Visitation

Good Intermittently Antagonistic

and Provocative

No Visit, or Destructive and Continually Provocative

Behavior Throughout Visit

Bonding with the Alienator

Strong, Healthy Strong, Mildly to Moderately Pathological

Severely Pathological, Often Paranoid Bonding

Bonding with the Alienated

Parent Prior to the Alienation

Strong, Healthy, or Minimally

Pathological

Strong, Healthy, or Minimally

Pathological

Strong, Healthy, or Minimally Pathological

MILD MODERATE SEVERE

ALIENATOR’S SYMPTOM LEVEL

DIFFERENTIAL DIAGNOSIS OF THE THREE LEVELS OF PARENTAL ALIENATION SYNDROME (PAS) ALIENATORS

NOTE: Whereas the diagnosis of PAS is based upon the level of symptoms in the child, the court's decision for custodial transfer should be based primarily on the alienator's symptom level and only secondarily on the child's level of PAS symptoms

MILD MODERATE SEVERE

Frequency of Programming ThoughtsFrequency of Programming Thoughts Occasional Occasional Frequent Frequent Obsessive Obsessive

Frequency of ProgrammingFrequency of Programming Occasional Occasional Frequent Frequent Persistent Persistent

Frequency of Exclusionary Maneuvers Frequency of Exclusionary Maneuvers Occasional Occasional Frequent Frequent Whenever Whenever possible possible

ALIENATOR’S SYMPTOM LEVEL

DIFFERENTIAL DIAGNOSIS OF THE THREE LEVELS OF PARENTAL ALIENATION SYNDROME (PAS) ALIENATORS

NOTE: Whereas the diagnosis of PAS is based upon the level of symptoms in the child, the court's decision for custodial transfer should be based primarily on the alienator's symptom level and only secondarily on the child's level of PAS symptoms

MILD MODERATE SEVERE

Violation of Violation of Court OrdersCourt Orders

Occasional Occasional Occasional Occasional to frequent to frequent

Repeatedly Repeatedly

Success in Manipulating the Legal System to Success in Manipulating the Legal System to Enhance the Programming* Enhance the Programming*

Minimal Minimal attempts attempts

Occasional to Occasional to moderate success moderate success

Repeatedly Repeatedly successful successful

Risk of Intensification of Programming Risk of Intensification of Programming After Gaining After Gaining Primary CustodyPrimary Custody

Very low Very low Mild Mild to moderate to moderate

Extremely Extremely high to the high to the point of point of being almost being almost inevitable inevitable

* The alienator can rely on court delays and court reluctance and even refusal to penalize the alienator with such measures as posting a bond, fines, community service, probation, house arrest, incarceration, and custodial change.

DIFFERENTIAL TREATMENT OF THE THREE TYPESOF PARENTAL ALIENATION SYNDROME (PAS)

APPROACHESAPPROACHES MILDMILD MODERATEMODERATE SEVERESEVERE

Legal Legal ApproachesApproaches

Court ruling Court ruling that primary that primary custody shall custody shall remain with remain with

the alienating the alienating parent.parent.

Plan APlan A (Most Common) (Most Common)

1. Court ruling that 1. Court ruling that primary custody shall primary custody shall remain with the alienating remain with the alienating parent.parent.

2. Court appointment of 2. Court appointment of PAS therapist.PAS therapist.

3. Sanctions3. Sanctions

a. Post a Bonda. Post a Bond

b. Finesb. Fines

c. Community Servicec. Community Service

d. Probationd. Probation

e. House Arrest e. House Arrest f. Incarceration f. Incarceration

1. Court ruling 1. Court ruling that primary that primary custody shall be custody shall be transferred to the transferred to the alienated parent.alienated parent.

2. Court-ordered 2. Court-ordered transitional site transitional site programprogram

APPROACHES MILD MODERATE SEVERE

Legal ApproachesLegal Approaches

Plan B

(Occasionally Necessary)

1. Court ruling that primary custody shall be transferred to the alienated parent.

2. Court appointment of PAS therapist.

3. Extremely restricted visitation by the alienating parent, monitored to prevent indoctrinations.

Psychotherapeutic Approaches

None usually necessary.

Plans A and B Treatment by a court-

appointed PAS Therapist.

Transitional site program monitored by court-appointed

PAS therapist

ANOTHER APPROACH FOR TREATMENTANOTHER APPROACH FOR TREATMENT Dr. Richard A. Warshak’s book entitled “Dr. Richard A. Warshak’s book entitled “Divorce PoisonDivorce Poison,” Regan ,” Regan

Books, 2001, advocates a proactive response when a parent Books, 2001, advocates a proactive response when a parent encounters alienating behavior by the other parent. Dr. Warshak has encounters alienating behavior by the other parent. Dr. Warshak has a five point questionnaire to assist parents before criticizing the a five point questionnaire to assist parents before criticizing the another parent. I call them the “stop and think” test.another parent. I call them the “stop and think” test.

1. What is the real reason for revealing this information to the child?1. What is the real reason for revealing this information to the child?

2. Are my children being harmed by the behavior I am about to 2. Are my children being harmed by the behavior I am about to criticize? Or are they being harmed by not having the information I criticize? Or are they being harmed by not having the information I am about to reveal?am about to reveal?

3. How will it help the children to hear what I am about to tell them?3. How will it help the children to hear what I am about to tell them?

4. Do the possible benefits of revealing this to the children outweigh 4. Do the possible benefits of revealing this to the children outweigh the possible risks?the possible risks?

5. If I were happily married to my spouse, and I wanted to protect our 5. If I were happily married to my spouse, and I wanted to protect our children’s relationship with him or her, how would I handle the children’s relationship with him or her, how would I handle the situation?situation?

SeeSee, Warshak, 17-18., Warshak, 17-18.

Dr.Warshak’s Summary of Misdiagnosis Dr.Warshak’s Summary of Misdiagnosis Factors in PASFactors in PAS

1. Your child occasionally criticizes your ex but does not engage in a campaign 1. Your child occasionally criticizes your ex but does not engage in a campaign of denigration and does not refuse to spend time with the other parent.of denigration and does not refuse to spend time with the other parent.

2. Your child is antagonistic to both parents2. Your child is antagonistic to both parents

3. Mild occasional badmouthing but not a severe campaign of denegration.3. Mild occasional badmouthing but not a severe campaign of denegration.

4. You engage in parental alienation but are not successful. As Dr. Gardner 4. You engage in parental alienation but are not successful. As Dr. Gardner points out “The diagnosis of PAS is not made on the programmer’s efforts points out “The diagnosis of PAS is not made on the programmer’s efforts but the degree of success” in the child.but the degree of success” in the child.

5. Your child’s response is appropriate to severe mistreatment by the other 5. Your child’s response is appropriate to severe mistreatment by the other parent.parent.

6. You neither foster or influence the child’s alienation either overtly or 6. You neither foster or influence the child’s alienation either overtly or covertly but have tried to maintain a healthy relationship You neither foster covertly but have tried to maintain a healthy relationship You neither foster or influence the child’s alienation either overtly or covertly but have tried or influence the child’s alienation either overtly or covertly but have tried to maintain a healthy relationship between your ex spouse and the child.to maintain a healthy relationship between your ex spouse and the child.

7. Only transitory difficulty (reluctance or resistance) in going from home to 7. Only transitory difficulty (reluctance or resistance) in going from home to home.home.

8. Your child is selective when he doesn’t want to spend time with the other 8. Your child is selective when he doesn’t want to spend time with the other parent like when the new spouse is present.parent like when the new spouse is present.

SeeSee, Warshak, 82-83., Warshak, 82-83.

A LEGAL EXAMINATION OF PASA LEGAL EXAMINATION OF PAS An analysis of PAS from a legal perspective is contained in an An analysis of PAS from a legal perspective is contained in an

article by Carol S. Bruch, entitled “article by Carol S. Bruch, entitled “PAS and PA: Getting it PAS and PA: Getting it Wrong in Child Custody Cases,Wrong in Child Custody Cases,” American Bar Association, ” American Bar Association, Family Law Quarterly, Vol. 35, No. 3, Fall 2001, pages 527-552.Family Law Quarterly, Vol. 35, No. 3, Fall 2001, pages 527-552.

A summary of Professor Burch criticism is as follows:A summary of Professor Burch criticism is as follows:

1. You don’t need PAS to describe a child’s reluctance to visit a 1. You don’t need PAS to describe a child’s reluctance to visit a parent.parent.

2. Studies indicate a number of reasons for children not visiting 2. Studies indicate a number of reasons for children not visiting including being angry or uncomfortable with the other parent.including being angry or uncomfortable with the other parent.

3. Abuse allegations are more often true than false.3. Abuse allegations are more often true than false.

4. Wrong end of the microscope.4. Wrong end of the microscope.

5. 5. Nature cures all, Remedy is too extreme.Nature cures all, Remedy is too extreme.

6.6. Wrong parent gets custodyWrong parent gets custody

PUBLICIZING OF PASPUBLICIZING OF PAS Perhaps Professor Bruch harshest criticism (this is getting personal) Perhaps Professor Bruch harshest criticism (this is getting personal)

for Dr. Gardner and his work is for what she calls “the merchandising for Dr. Gardner and his work is for what she calls “the merchandising of PAS in child custody cases” and is as follows:of PAS in child custody cases” and is as follows:

1.1. Dr. Gardner is not a “full professor at a prestigious university.” Dr. Gardner is not a “full professor at a prestigious university.”

2.2. Dr. Gardner is mostly self published. Dr. Gardner is mostly self published.

3.3. Dr. Gardner’s work lacks scientific rigor.Dr. Gardner’s work lacks scientific rigor.

4.4. Dr. Gardner’s works are not found in most university and research Dr. Gardner’s works are not found in most university and research libraries.libraries.

5.5. Dr. Gardner has his own website and gets referrals from other Dr. Gardner has his own website and gets referrals from other websites of “fathers organizations.” See Appendix V for web sites websites of “fathers organizations.” See Appendix V for web sites dealing with PAS.dealing with PAS.

6.6. Dr. Gardner packages educational courses for other professionals.Dr. Gardner packages educational courses for other professionals.

7.7. Dr. Gardner presents or suggests PAS is consistent or endorsed and Dr. Gardner presents or suggests PAS is consistent or endorsed and accepted by other professionals.accepted by other professionals.

HARSH CRITICISM OF DR. HARSH CRITICISM OF DR. GARDENER AND PASGARDENER AND PAS

Dr. Paul J. Fink, past president of the American Dr. Paul J. Fink, past president of the American Psychiatric Association and President of the Psychiatric Association and President of the Leadership Council on Mental Health Justice and Leadership Council on Mental Health Justice and the Media states as follows:the Media states as follows:

““PAS as a scientific theory has been excoriated by PAS as a scientific theory has been excoriated by legitimate researchers across the nation. Judged legitimate researchers across the nation. Judged solely on his merits, Dr. Gardner should be a solely on his merits, Dr. Gardner should be a rather pathetic footnote or an example of poor rather pathetic footnote or an example of poor scientific standards.”scientific standards.”

MAYBE IT’S A MISNOMERMAYBE IT’S A MISNOMER

Professor Bruch points out that some Professor Bruch points out that some professionals reject PAS but have adopted the professionals reject PAS but have adopted the term “estrangement” which is similar to term “estrangement” which is similar to alienation but use the term to “refer to difficulties alienation but use the term to “refer to difficulties in a noncustodial parent’s relationship with a in a noncustodial parent’s relationship with a child that can be traced to that parent’s child that can be traced to that parent’s characteristic or behavior. “Alienation” in their characteristic or behavior. “Alienation” in their usage refers to difficulties stemming from the usage refers to difficulties stemming from the child’s misappropriate, persistent and child’s misappropriate, persistent and unreasonable negative feelings toward a parent.” unreasonable negative feelings toward a parent.”

TRANSITORY - SELF CURINGTRANSITORY - SELF CURING

Dr. Wallerstein is quoted as saying that issues of Dr. Wallerstein is quoted as saying that issues of alignment are transient and self resolving within alignment are transient and self resolving within one or two years and all by the age of eighteen.. one or two years and all by the age of eighteen.. Therefore, Dr. Gardner’s recommendation of Therefore, Dr. Gardner’s recommendation of dramatic removal and displacement are dramatic removal and displacement are unnecessary as a means of resolution of PAS. Dr. unnecessary as a means of resolution of PAS. Dr. Wallerstein compares PAS to the flu and not a Wallerstein compares PAS to the flu and not a cancer requiring radical surgery.cancer requiring radical surgery.

REMOVAL - TOO EXTREME REMOVAL - TOO EXTREME CURECURE

“ “It has been our experience that forcibly removing It has been our experience that forcibly removing

...children from the aligned parent and placing ...children from the aligned parent and placing them in the custody of the rejected parent, as them in the custody of the rejected parent, as recommended by Gardner (1987) is a misguided recommended by Gardner (1987) is a misguided resolution; it is likely to be not only ineffective but resolution; it is likely to be not only ineffective but actually punitive and harmful because it actually punitive and harmful because it intensifies the problem.” See, Johnston, Children intensifies the problem.” See, Johnston, Children Who Refuse to Visit, at 132.Who Refuse to Visit, at 132.

ADMISSIBILITY OF PASADMISSIBILITY OF PAS

The admissibility of PAS in a The admissibility of PAS in a Daubert/RobinsonDaubert/Robinson challenge challenge can be messy. Fortunately, there is assistance through the can be messy. Fortunately, there is assistance through the State of Texas, Family Law Section, Expert Witness Manual. State of Texas, Family Law Section, Expert Witness Manual. See,See, State Bar of Texas, Family Law Section, State Bar of Texas, Family Law Section, Psychological Psychological Syndromes: Parental Alienation SyndromeSyndromes: Parental Alienation Syndrome, by Dr. Richard A. , by Dr. Richard A. Warshak, Chapter 3-32 (1999).Warshak, Chapter 3-32 (1999).

A. Common Issues and Critical AnalysisA. Common Issues and Critical Analysis

B. Dependability and AuthenticityB. Dependability and Authenticity

C.C. Does PAS Unfairly Blame One Parent?Does PAS Unfairly Blame One Parent?

D. Testimony on PASD. Testimony on PAS

E. Opposing AdmissibilityE. Opposing Admissibility

THE FUTURETHE FUTURE PAS will continue to be used and abused. Whether the PAS will continue to be used and abused. Whether the

underlying behavior of parents and children should be underlying behavior of parents and children should be called alienation, alignment or just responses to parents called alienation, alignment or just responses to parents separating or divorcing will continue for many years to separating or divorcing will continue for many years to come. The family practitioner and family law judges will come. The family practitioner and family law judges will be on the forefront of challenging and/or corroborating be on the forefront of challenging and/or corroborating this condition regardless of nomenclature. Most family this condition regardless of nomenclature. Most family law practitioners and judges have observed law practitioners and judges have observed inappropriate parental conduct with children with regard inappropriate parental conduct with children with regard to the other parent. And many family law practitioners to the other parent. And many family law practitioners have observed children distancing themselves from one have observed children distancing themselves from one parent or the other in the context of divorce and parent or the other in the context of divorce and modification suits. A single act by a parent could modification suits. A single act by a parent could constitute an act of parental alienation but not be constitute an act of parental alienation but not be labeled PAS. It is extremely important to focus on the labeled PAS. It is extremely important to focus on the conduct and response regardless of names and we conduct and response regardless of names and we should all be concerned that a name or syndrome not should all be concerned that a name or syndrome not produce a preordained result.produce a preordained result.

CONCLUSIONCONCLUSION

After a comprehensive review of the clinical and After a comprehensive review of the clinical and research literature relevant to PAS, Dr. Rand concludes:research literature relevant to PAS, Dr. Rand concludes:

Whether or not one chooses to use Gardner’s Whether or not one chooses to use Gardner’s terminology, the problems posed by these cases to terminology, the problems posed by these cases to families, professionals and the courts are very real. families, professionals and the courts are very real. Reluctance to consider Parental Alienation Syndrome by Reluctance to consider Parental Alienation Syndrome by name, along with the diagnostic [sic] and interventions name, along with the diagnostic [sic] and interventions it entails, tends to contribute to the perpetuation of the it entails, tends to contribute to the perpetuation of the problem in a variety of ways. Like any other label, that problem in a variety of ways. Like any other label, that of PAS had the potential to be misapplied and of PAS had the potential to be misapplied and misused... An appropriate diagnosis of PAS, including misused... An appropriate diagnosis of PAS, including level of severity as Gardner recommends, can make level of severity as Gardner recommends, can make the difference between allowing a case to go beyond the difference between allowing a case to go beyond the point of no return or intervening effectively before the point of no return or intervening effectively before it is too late.it is too late.

DIFFERENTIAL DIAGNOSIS OF THE THREE TYPES OF PAS

MILD MODERATE SEVEREThe Campaign of Denigration Minimal Moderate Formidable

Weak, Frivolous, or Absurd Rationalizations for the

Deprecation

Minimal Moderate Multiple Absurd Rationalizations

Lack of Ambivalence Normal Ambivalence No Ambivalence No Ambivalence

The Independent-Thinker Phenomenon

Usually Absent Present Present

Reflexive Support of the Alienation Parent in the Parental

Conflict

Minimal Present Present

Absence of Guilt Normal Guilt Minimal to no Guilt No Guilt

Borrowed Scenarios Minimal Present Present

Spread of the Animosity to the Extended Family and Friends of

the Alienated Parent

Minimal Present Formidable, or Visit not Possible

Transitional Difficulties at the Time of Visitation

Usually Absent Moderate Formidable, or Visit not Possible

Behavior During Visitation Good Intermittently Antagonistic and Provocative

No Visit, or Destructive and Continually Provocative

Behavior Throughout Visit

Bonding with the Alienator Strong, Healthy Strong, Mildly to Moderately Pathological

Severely Pathological, Often Paranoid Bonding

Bonding with the Alienated Parent Prior to the Alienation

Strong, Healthy, or Minimally Pathological

Strong, Healthy, or Minimally Pathological

Strong, Healthy, or Minimally Pathological

ALIENATOR’S SYMPTOM LEVEL

DIFFERENTIAL DIAGNOSIS OF THE THREE LEVELS OF PARENTAL ALIENATION SYNDROME (PAS) ALIENATORS

NOTE: Whereas the diagnosis of PAS is based upon the level of symptoms in the child, the court's decision for custodial transfer should be based primarily on the alienator's symptom level and only secondarily on the child's level of PAS symptoms

MILD MODERATE SEVERE

Frequency of Programming ThoughtsFrequency of Programming Thoughts Occasional Occasional Frequent Frequent Obsessive Obsessive

Frequency of ProgrammingFrequency of Programming Occasional Occasional Frequent Frequent Persistent Persistent

Frequency of Exclusionary Maneuvers Frequency of Exclusionary Maneuvers Occasional Occasional Frequent Frequent Whenever Whenever possible possible

Violation of Violation of Court OrdersCourt Orders

Occasional Occasional Occasional Occasional to frequent to frequent

Repeatedly Repeatedly

Success in Manipulating the Legal System to Success in Manipulating the Legal System to Enhance the Programming* Enhance the Programming*

Minimal Minimal attempts attempts

Occasional to Occasional to moderate success moderate success

Repeatedly Repeatedly successful successful

Risk of Intensification of Programming Risk of Intensification of Programming After Gaining After Gaining Primary CustodyPrimary Custody

Very low Very low Mild Mild to moderate to moderate

Extremely Extremely high to the high to the point of being point of being almost almost inevitable inevitable

* The alienator can rely on court delays and court reluctance and even refusal to penalize the alienator with such measures as posting a bond, fines, community service, probation, house arrest, incarceration, and custodial change.

DIFFERENTIAL TREATMENT OF THE THREE TYPE (PAS)

APPROACHESAPPROACHES MILDMILD MODERATEMODERATE SEVERESEVERE

Legal ApproachesLegal ApproachesCourt ruling that Court ruling that

primary custody shall primary custody shall remain with the remain with the

alienating parent.alienating parent.

Plan APlan A (Most Common) (Most Common)1. Court ruling that primary 1. Court ruling that primary custody shall remain with the custody shall remain with the alienating parent.alienating parent.2. Court appointment of PAS 2. Court appointment of PAS therapist.therapist.3. Sanctions3. Sanctions a. Post a Bonda. Post a Bond b. Finesb. Fines c. Community Servicec. Community Service d. Probationd. Probation e. House Arrest e. House Arrest f. Incarcerationf. IncarcerationPlan B(Occasionally Necessary)1. Court ruling that primary custody shall be transferred to the alienated parent.2. Court appointment of PAS therapist.3. Extremely restricted visitation by the alienating parent, monitored to prevent indoctrinations.

1. Court ruling that 1. Court ruling that primary custody shall be primary custody shall be transferred to the alienated transferred to the alienated parent.parent.2. Court-ordered 2. Court-ordered transitional site programtransitional site program

Psychotherapeutic Approaches None usually necessary.

Plans A and B Treatment by a court-

appointed PAS Therapist.

Transitional site program monitored by court-appointed

PAS therapist