THE ART AND SCIENCE OF CHILD CUSTODY EVALUATIONS

THE ART AND SCIENCE OF CHILD CUSTODY EVALUATIONS

Integrating Clinical and Forensic Mental Health Models

Jonathan W. Gould and Philip M. Stahl

Should a child custody evaluation be a clinical tool informed by forensic methods and procedures or a forensic tool informed by clinical experience? The authors conclude that an evaluation requires a delicate blend of scientific thinking, clinical understanding, thorough observations, appropriate use of psychological tests, and self-report measures and information from sufficient collateral sources. Evaluators must pay attention to internal biases and integrate them with the relevant literature. Finally, evaluators must remember that their evaluation and reports will be used by both the courts and the family in reaching a decision on behalf of the children.

Whereas Stahl’s (1994,1999) model focuses on using the evaluator’s clinical skills to help a family understand its child’s best interests and settle its dispute out of court, Gould’s (1998, 1999b) model focuses on the development of methods and procedures that are founded on behavioral science research and meet legal standards of admissibility. Although it would appear that the emphasis is somewhat different, the approaches converge and the intentions and goals are often identical. We are interested in developing a model of child custody evaluation that helps families resolve their conflicts and provides the court with a useful, legally relevant work product. After parents separate, the core of our concern is a commitment to helping children of divorcing families find a balance in their lives as quickly and as free of conflict as possible.

There is little discussion in the literature about how to blend the two models into an integrated, ethically appropriate, and legally useful tool. This article is an attempt to begin this dialogue and create a bridge between clinically focused, settlement-based child custody evaluations and those that are more consistent with the goals of a forensic mental health evaluation geared to the needs of the court.

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MORALITY OF THE ROLE OF AN EXPERT WITNESS

We begin our discussion with a brief examination of the moral foundation for expert witness testimony and ask the question, What should guide moral expert witness testimony? According to Lavin and Sales (1998), “There are differences between legal, ethical, and moral bases for behavior. Moreover, these differences play a substantial part in our analysis of what the role of psychologist as expert witness ought to be” (p. 62).

In a provocative and compelling chapter, Lavin and Sales (1998) argued that there are moral justifications for placing limitations on expert witness testimony. Courts have had to rely on admissibility rules to determine who will be recognized as an expert. Qpically, these rules focus on the person’s qualifications such as those articulated in the Federal Rules of Evidence ($702) and the corresponding state rule of evidence. To qualify as an expert witness, questions are asked about training, skill, experience, and education, as well as other areas of consideration. The qualification of an expert is a judgment made by the trier of fact.

Being an expert is different from having expertise. A field of knowledge is an area of expertise if it is generally viewed as an area of real knowledge (Lavin & Sales, 1998). One may hold, for example, expertise in mental health and behavioral sciences, or in the areas of divorce, child development, or evaluation. The real question to be asked, however, is, What can we have expert opinions about and how ought those opinions be offered as evidence?

Moral theories often agree about moral principles, even when they dis- agree about the underlying epistemology of those principles (Lavin & Sales, 1998). We briefly review three types of moral theories that have a strong basis in Anglo-American moral thought. In addition, each review asks the question, What is the character of moral expert witness testimony?

The moral philosophy of consequentialism (Lavin & Sales, 1998) views the rightness or wrongness of an action, whether directly or indirectly, on its consequences. Applied to expert witness testimony, consequentialism sup- ports a mental health professional refusing to testify as an expert, except when he or she has scientific expertise to contribute. It is evident that moral behavior is that which has a positive or desired outcome. In contrast, im- moral behavior is that which is founded on bad outcome, exemplified in this case as nonscientific testimony presented under the guise of expert witness testimony. When a mental health professional offers expert opinions that are not supported by scientific fact, that professional fails to meet a consequentialist duty to work to secure the best expected outcome.

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The moral philosophy of deontology (Lavin & Sales, 1998) views the rightness or wrongness of an act based on its respect for individual autonomy through veracity. In this regard, emphasis is placed on treating each person with respect and never treating h m or her solely as a means to an end. The failure to attain veracity (accuracy, truth) involves using other persons as a means to an end, which is a violation of their ontological purpose, or reason for being. The root wrong of lying is that it prevents people from acting autonomously; therefore, those people are not respected as ends in themselves (Lavin & Sales, 1998). As applied to expert witness testimony, mental health experts, when they testify, are assuming themantle of truth. Their duty to maintain veracity requires that expert witnesses give no testimony that is likely to create false beliefs about what truths the behavioral sciences offer. Regardless of whether testimony is admissible under current law as opinion testimony, if the expert does not know the relevant science or if the means used to determine the expert testimony are not based on scientific methods and procedures determined to be useful in forensic examinations, the mental health professional should either not testify or state the limits of the testimony.

The moral philosophy of virtue ethics (Lavin & Sales, 1998) seeks mor- ally desirable properties of human behavior. Although it is often difficult to define these virtues precisely, and impossible to define all possible virtues, there is consensus among many students of moral philosophy that courage, temperance, justice, conscientiousness, and honesty are among the virtues considered universally relevant. Moral behavior, then, reflects the consistent and positive use of all of these virtues.

The role of the expert witness places a constraint on virtuous behavior. The failure to offer accurate facts falls short of the conscientious behavior that is expected by virtue ethics. The moral obligation of an expert witness is not to offer opinions in place of knowledge; rather, mental health experts come to court because of their presumed specialized knowledge about the behavioral sciences. In providing testimony, moral behavior reflects the limits of that knowledge.

Applying this brief overview of moral philosophy to the role of the child custody evaluator yields the following conclusions. The moral character of an expert witness who engages in the practice of child custody evaluations is based on the consistent and positive use of virtues. Furthermore, the moral character of the expert is based on him or her assiduously attending to veracity, knowledge, and truth while working toward the best possible outcome. This means, therefore, that the morality of expert witness testimony reflects the consistent and positive use of the highest standards of professional behavior, a concept similar to that discussed in the American Psychological Asso-

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ciation’s (APA) (199 1) Specialty Guidelines for Forensic Psychologists. These standards include but are not limited to the use of current behavioral science literature to inform every aspect of the evaluation process, the choice of evaluation methods and procedures that reflect the current state of the art, and an articulation of the behavioral science basis on which conclusions and recommendations are made. Similarly, the moral evaluator maintains a virtuous stance with regard to the clarity of the boundaries and limitations of his or her professional role.

We begin with amost fundamental question: What is the purpose of a child custody evaluation? The answer to this question is both simple and complex.

THE SIMPLE ANSWER

The simple answer is that the purpose of a custody evaluation is clearly articulated in professional practice guidelines established by the APA and the Association of Family and Conciliation Courts (AFCC). It is also consistently echoed in books, textbooks, and articles that serve to define our field of professional endeavor.

The APA’s (1994) “Guidelines for Child Custody Evaluations in Divorce Proceedings” suggest that the focus of a child custody evaluation is “to assess the individual and family factors that affect the psychological ‘best interests of the child.’ More specific questions may be raised by the court” @. 677). Toward this end, the APA recommends an evaluation of parental fitness, the psychological and developmental needs of the child, and the resulting fit between each parent’s parenting competencies and the needs of the minor child, To accomplish this goal, a child custody evaluation should involve an assessment of each parent’s capacities for parenting; an assessment of the psychological functioning and developmental needs of the child and the wishes of the child where appropriate; and an assessment of the functional ability of each parent to meet the needs of the child, which includes an evaluation of the interaction between each adult and the child (APA, 1994).

The AFCC’s (1995) Model Standards of Practice for Child Custody Eval- uation suggest that

child custody evaluation is a process through which recommendations for the custody of, parenting of, and access to children can be made to the court in those cases in which the parents are unable to work out their own parenting plans. . . . The primary purpose of a child custody evaluation is to assess the family and provide the courts, the parents, and the attorneys with objective information and recommendations. (p. 1)


Toward this end, the AFCC’s Model Standards recommend the following evaluations: (a) identify the developmental needs of the child; (b) identify strengths, vulnerabilities, and needs of all other members of the family; (c) identify the positive and negative family interactions; (d) develop a plan for custody and access using the strengths of each individual that will serve the best interests of the child and, within those parameters, the wishes and interests of the parents, and in most situations provide parents with an opportunity to share in the upbringing of their child; and (e) through a written report, provide the court, parents, and attorneys with these recommendations and supporting data (p. 1).

There are also several authoritative textbooks that mirror the standards described by the M A and the AFCC. For example, Melton, Petrila, Poythress, and Slobogin (1997, p. 502), in Psychological Evaluations for the Courts: A Handbook for Mental Health Professionals and Lawyers, suggest a “clinical inquiry” in custody evaluations based on a model developed by R. K. Otto. This model affords highly relevant data about the “fit” between the child’s needs and the parents’ competencies. This model may include the following: parents’ prior and current relationship with the children and responsibility for caretaking; type and nature of discussions about divorce with the children; parental attitudes about each other and how they are or are not conveyed to the children; each parent’s goals for visitation and decision making should he or she be awarded custody; parent-child interactional style; parents’ current, anticipated living and working arrangements; each parent’s emotional functioning and mental health; child’s preferences; child’s depiction and concep- tualization of his or her relationship with each parent; and child’s emotional, social, and academic functioning and mental health prior to and after the divorce.

Grisso (1986) argued that a custody evaluation is, in large part, an evaluation of parenting competencies. Grisso’s model of competency evaluation guides the evaluator in developing a framework for data gathering, generat- ing inferences, making decisions, and developing recommendations that are both useful and reflective of important professional practice standards.

Grisso’s (1986) parental competency model suggests several objectives for competency evaluations. The first factor examines a parent’s strengths and deficits in the specific abilities defined by the legal standard. The second objective examines the causes of any deficits in abilities that have been observed. The evaluator examines the litigant within a specific context or role. The third objective assesses how the deficits in abilities affect behaviors that are of concern to the primary legal question. The evaluator is concerned with identifying and describing the causes of observed deficiencies related to the psycholegal questions guiding the assessment. The assessment of a

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child’s developmental needs becomes an assessment of the functional competencies of each child. Once accomplished, a comparison of the goodness of fit between a parent’s observed functional competencies and those of the child can be made. A final objective is that of providing information to the court about “matters of remediation or other dispositional options” (p. 21).

We have discussed the purpose of custody evaluations in our respective work (Gould, 1998, 1999b; Stahl, 1994, 1999) and agree that the recommended professional guidelines written by the APA and the AFCC provide an important framework within which evaluators should conduct their work.

Gould and colleagues (Kirkpatrick, personal communication, October 10, 1999) argue that the APA guidelines need to include another dimension to evaluate. In considering that custody and visitation disputes typically arise out of the interactional dynamics of the parents, it makes sense for the evaluator to assess the marital and family context that likely fuels the dispute. A competent child custody evaluation includes four factors: the marital and family context, the parentdcaretakers, the children, and the resulting fit or goodness of fit between the aforementioned factors. Kirkpatrick believes that this concept goes beyond that recommended by the AFCC in the third criteria for evaluating families in child custody disputes. Rather than focus on identifying the positive and negative family interactions, as suggested by the AFCC, Kirkpatrick suggests that evaluators need to understand the family’s historical context, the relationship dynamics between and among family members, and the nature and quality of narcissistic injury that has affected each family member, particularly each parent.

Relative Versus Absolute Standards of Practice in Conducting Child Custody Evaluations

Although we would like to propose a set of practice standards that provide a unitary set of methods and procedures for use in child custody evaluations, we recognize that this field is not sufficiently developed; nor is there sufficient consensus among scholars and practitioners of child custody to propose professional practice standards. Individual practitioners will approach child custody evaluations differently depending on their unique skills, training, and experience, as well as the particular needs of a given assessment. For example, psychological testing may be unnecessary, and in fact inappropri- ate, if there exist test results from another source that provide the data needed for the evaluation process. Furthermore, we do not want to limit, in light of the current state of the art, one practitioner’s choice to use a particular battery of tests. In contrast, we would argue that each practitioner needs to be competent in both administering the chosen instrument and providing a good foren-


sic interpretation, as well as be knowledgeable about the standards of admissibility applied to the test within his or her own jurisdiction. For those who do not use testing because of either limitations in their training or the prevailing culture of their community, we suggest that such practitioners be prepared to defend their practice of not using psychological tests. Practitioners can pre- pare by becoming knowledgeable about current research and practice in the field of custody assessment and framing their decision within a properly rea- soned, scientifically based argument.

Our work, in addition to the work of other experts (i.e., the published professional guidelines of the AFCC, the APA, and the American Psychiatric Association), is intended to provide a conceptual framework and a practical application of current forensic psychological literature in child custody evaluations. We recognize that guidelines and recommended procedures can be misused and/or misunderstood by well-intentioned people. Although competent and well-intentioned practitioners may differ in how they conduct a proper child custody evaluation, it is necessary that each practitioner logi- cally, coherently, and competently defend his or her approach to a child custody evaluation from within the framework of the behavioral science literature.

One way to increase the fit between a child custody evaluation and legal standards of admissibility of scientific expert evidence/testimony is to scientifically craft the child custody evaluations. A scientifically crafted forensic work product uses the methods and procedures of the scientific method in the gathering, analysis, and interpretation of data. A scientifically crafted child custody evaluation bases its recommendations on the behavioral science literature (Gould, 1998, 1999b). Toward this end, we propose two different ideas about how to approach a child custody evaluation in a scientific manner: scientific thinking and scientific methods.

Scientific Thinking

There are two ways to integrate a scientific approach to child custody evaluations. The first approach is to think scientifically. Scientific thinking involves systematically organizing data gathered during a custody evaluation into observations, inferences, and hypotheses. We have noted how often a practitioner presents information in a report that confuses observations from the inferences drawn from those observations. For the record, observations are things that we can see, hear, feel, or smell. An observation is a piece of data. It has no inherent meaning or value other than being a piece of information that, when combined with other pieces of data, may be interpreted to mean something. The inferences drawn from these pieces of information

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may be interpreted to mean something. The meanings are then used to create hypotheses that guide the conclusions and recommendations set forth in our report.

The interpretation of data creates the meaning we assign to the data. The importance of the meanings we assign to different data is based on assump- tions and models of human behavior. It is in this area that practitioners differ in their use of data. The meaning they take from a set of data reflects the theoretical models that guide their thinking. For example, if I believe in the tender years doctrine, then the meaning I draw from a custodial mother’s care of her 2-year-old compared with the care provided by the father will, most probably, be filtered through this theoretical perspective concerning what is in the best psychological interests of the child. We assert that all child custody evaluators have some beliefs (some might call them biases) that guide their thinking and feel that the moral child custody evaluator is aware of these beliefs and understands where they come from. This framework is critical, because the legal basis for child custody decisions in all 50 states is the best interests of the child, a vague concept in search of a practical meaning.

We have noted that many practitioners do not distinguish the observations they record from the inferences and hypotheses they develop from the observational data. We strongly suggest that practitioners learn and consistently apply the scientific model of thinking mentioned above to their evaluation process, and that practitioners display these distinctions when writing or talk- ing about their work. Families, attorneys, and judges need to know not only the inferences drawn from those data but also the observational data from which they make their recommendations. We also suggest that practitioners be willing to make their beliefs (biases) clear to help parents, attorneys, and judges understand the interaction between the observational data, practitioners’ beliefs, and the inferences and conclusions produced by such beliefs.

Following the scientific method, a custody evaluator tests a set of rival hypotheses related to a given case (Gould, 1998; Greenberg & Shuman, 1997). The impartial expert needs to be familiar with the relevant case law and how it relates to the questions posed by the court for evaluation. Finally, a child custody evaluation must be reliable and valid to areasonable degree of scientific certainty for it to be admissible as evidence (Greenberg & Shuman, 1997).

In gathering data that are used to test each rival hypothesis, the forensic evaluator offers opinions with regard to historical truth and the validity of the psychological aspects of a party’s claims. Unlike therapy, in which information is often based on what is provided by the patient and therefore may be somewhat incomplete, grossly biased, or honestly misperceived, a competent child custody evaluation includes an examination of the accuracy


of each party’s story in addition to other informational sources (Greenberg & Shuman, 1997).

Scientific Methods

We have stressed the need to use a set of methods and procedures that reflect current behavioral science thinking and research in child custody assessment, as well as current legal expectations about the admissibility of scientific evidence. Although we differ in the relative weight we assign to each factor, we acknowledge that a properly crafted child custody evaluation follows the methodological framework presented below.

Use of a structured forensic interview protocol. Although there are no published structured interview protocols specifically designed for custody matters, it may make sense to consider developing a forensically sound structured interview for the parents. Structured forensic interview protocols provide systematic comparisons, with the form and sequencing of questions being held constant. Parents’ responses can be examined for consistency on three parameters: across time (identical questions at different times), with collateral informants (collateral interviews with identical questions), and with unstructured narrative (a parent’s free-flowing account with structured questions) (Rogers, 1998).

To help avoid evaluator bias, we recommend that the custody evaluator develop a comprehensive and representative list of questions and assessment areas. These should be anchored to the referral questions and explored with each party in a consistent manner. Although no standardized custody/visitation interviews exist, some self-report questionnaires related to parenting and custody issues are available (see Greenberg, 1996; Gould, 1999a). Stahl (1994) provides a comprehensive list of sample questions to ask parents andlor children that can be used to standardize one’s interview questions. Using a family systems theory as a framework, Gould (1998) created a parenting questionnaire that reflected a useful theoretical paradigm. The custody evaluator might consider using the parties’ responses to self-report questionnaires as a basis for the forensic interview. In this manner, standard- ization and reliability can be promoted to the greatest extent possible.

The conclusion in the forensic literature is that in using a standard forensic interview protocol, a more scientific method of data collection is provided, with the results increasing the reliability of the data (Rogers, 1995, 1997, 1998). Thus, the use of a standard forensic interview protocol provides a more systematic means of data gathering in a manner consistent with the evi- dentiary needs of scientific information (Gould, 1998). The custody evalua-

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tor is encouraged to develop a standardized approach to the entire evaluation (not just the interviews), which will enhance the reliability and validity of the evaluation process.

Evaluators who choose not to use a standard forensic interview protocol should be prepared to defend their choice of an alternative interview method. Their defense would include a discussion of the contrast between the current forensic literature and their method, emphasizing how their method is a forensically sound, legally defensible alternative. They should also be prepared to explain how the employed interview method reflects their understanding of the current best practice, as well as the advantages of their method in comparison with methods discussed in the literature.

Self-report measures. Another core data-gathering component is self- report measures. Often, self-report measures used in child custody evaluations include parenting stress, parenting satisfaction, parent-child relationship, emotional well-being, parent perception of the child, child perception of the parent, parent perception of the parent-child relationship, and child perception of the parent-child relationship (Ackerman, 1995; Ackerman & Ackerman, 1997; Schutz et al., 1989). The information obtained from self- report measures is subject to confirmation from other sources such as direct behavioral observation and collateral interviews. According to Brodzinsky (1993), “Certain questionnaires and behavior rating scales also allow the evaluator to assess how the parties view one another in various domains of functioning” (p. 215).

Similar to psychological tests (discussed in the next subsection), results from self-report measures should be used to generate hypotheses about each parent or child. These measures have lower psychometric integrity than traditional psychological tests. One particular cause of lower psychometric integrity is the lack of validity scales on most of these self-report measures, which makes it difficult to ascertain whether a person is trying to purposely fake (good or bad) his or her responses. Another concern about many of the instruments ostensibly developed for child custody evaluations is the lack of a scientific foundation for interpreting them (for more details, see Otto, Edens, & Barcus, 2000 [this issue]). However, if results from the measures are used to explore alternative hypotheses, awaiting confirmation from alternative data sources, then self-report measures often can be extremely useful instruments.

Some self-report measures will meet the criteria for a psychological test (i.e., Heilbrun, 1995) and some of the criteria necessary for admissibility as a scientific test (Goodman-Delahunty, 1997). Many self-report measures are supported by an underlying theory of science, which increases their reliability and validity. Furthermore, many self-report measures are testable through

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scientific investigation, published in peer-reviewed journals, and generally accepted for use among those in the professional community (e.g., Beck Depression Inventory, Parent-Child Relationship Inventory). In effect, these are the most useful self-report measures.

There are also self-report measures that are not scientific instruments in that they fail to meet Heilbrun’s (1995) criteria for a psychological test. The usefulness of such measures is therefore more limited. However, because they are standard data-gathering tools, they do have some value. The evaluator should use the data derived from such measures with caution when gener- ating hypotheses and be certain to corroborate any conclusions from other data sources. Self-report measures that fall into this category include questionnaires, surveys, and some checklists.

Whether or not an evaluator uses self-report measures, he or she needs to be prepared to defend the decision about the use of such measures. The defense should include a discussion of the current forensic literature con- trasted with the evaluator’s method and emphasize how the method provides a forensically sound, legally defensible alternative to recommendations that are reflected in the current literature. The evaluator should also be prepared to explain how the choice to use or not to use self-report measures increases the reliability and validity of the evaluation results. Finally, the evaluator should be prepared to describe how using or not using self-report measures reflects the understanding of the current best practice, as well as the advantages of those measures when compared with data-gathering methods described in the literature. Some evaluators who use self-report measures as a screening tool must make the intended purpose of the instrument clear.

Standardized psychological tests. An important source of data gathering is the use of standardized psychological tests. The choice of a psychotogical test should be directly relevant to the psycholegal questions being posed (i.e., Griggs v. Duke Power, 1971). For example, in the assessment of parental competencies, several personality tests are available that may generate hypotheses relevant to personality features that influence the individual’s parenting (e.g., MMPI-2, Rorschach). It is important to note that there is no personality test that directly measures parenting or parental competencies. Rather, some tests provide data that can be related to such parental competencies (e.g.. impulse control, emotional stability).

The use of psychological tests within acustody/visitation evaluation is not without professional disagreement. According to Melton et al. (1997),

One of the more controversial issues in the child custody literature is the proper role for traditional psychological tests in the assessment process. . . . The little

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data that exist concerning the practices of mental health professionals in custody assignments suggest that theuse of conventional tests is routine. (p. 501)

Melton et al. add a cautionary note: “Thus, apparent practices notwith- standing, we recommend the use of traditional psychological tests only when specific problems or issues that these tests were designed to measure appear salient in the case” @. 503). It is therefore important for the custody evaluator to develop a rationale for test selection. Testing might be quite useful, for example, when one suspects that either of the parties might have apersonality disorder that is affecting the dynamics of the custody dispute. This is particularly probable for high-conflict postdivorce cases in which custody issues have been litigated for years. Rather than using a shotgun approach to test choice, evaluators should narrow their choice of tests to those that provide relevant data related to the psycholegal questions posed by the court.

The use of psychological test data in court should provide, among other sources of information, a genuinely empirical basis for an expert’s opinion (Shapiro, 1991). Psychological testing has the potential of providing objective support to the expert’s opinion (Shapiro, 1991). A properly developed standardized test should provide the expert with data grounded in objective, empirical research (Heilbrun, 1992,1995). Furthermore, the use of psychological tests helps to balance the bias and potential errors inherent in clinical interview data with objective results (Ben-Porath, Graham, Hall, Hirsch- man, & Zaragoza, 1995; McCann & Dyer, 1996). However, it is critical for the evaluator to understand that any test results provide only hypotheses that are subject to verification from alternative data sources (Heilbrun, 1992).

Tests also provide information about the individual’s response style and bias. Included among the variables critical for making objective assessments in a custody evaluation is the degree to which a parent (or child) may be attempting to present himself or herself in a favorable light. Despite our often- held belief that skilled interviewers are able to distinguish through the interview procedure who is lying and who is telling the truth, years of research have clearly demonstrated that mental health professionals are not very good at judging who is honest and who is not (Wiggins, 1979). Thus, the evaluator needs to be aware of potential deception and malingering among adults (Rogers, 1997,1998) and among children (Oldershaw & Bagby, 1997). There is also an emerging literature about custody litigants’ profiles on some clinical measures (see Bathurst, Gottfried, & Gottfried, 1997; McCann & Hens, 1998). As Brodzinslq (1 993) stated,

Psychological testing has a very legitimate place in child custody assessments. Besides providing psychological data about the unique strengths, limitations


and dynamics of the individuals involved, testing permits observation of each party under controlled conditions and allows theevaluator to objectively examine the person’s approach to the assessment itself (i.e., whether the individual shows any particular response bias, such as faking good or faking bad, in the evaluation). (p. 215)

Important aspects of choosing a psychological test include its acceptance as scientific evidence in previous jurisdictions, published psychometric data supporting its reliability and validity, its relevance to psycholegal questions, and a basis in scientific theory (Ben-Porath et al., 1995; McCann & Dyer, 1996; Pope, Butcher, & Seelen, 1993). Furthermore, a psychological test should be viewed as a tool generally relied on by professionals in the field for use in custodial matters (Ackerman & Ackerman, 1997). It should assist in the generation of hypotheses that are directly related to the psycholegal questions posed by the court.

A final area of importance when deciding on a standardized psychological test is to choose a test with which the evaluator is comfortable in administering, knowledgeable about both its forensic applicability and legal admissibility, and competent in its forensic use and interpretation.

An evaluator who chooses not to employ standardized psychological tests should be prepared to defend the decision not to use such measures. The defense should include a discussion of the current forensic literature con- trasted with the evaluator’s method and emphasize how that method provides a forensically sound and legally defensible alternative to recommendations that are reflected in the current literature. The evaluator should also be prepared to explain how the choice not to use psychological tests increases the reliability and validity of the evaluation results. In light of the recent Ackerman and Ackerman (1997) article, which reported that more than 90% of psychologist custody evaluators use some standardized psychological tests, the evaluator, if he or she is a psychologist, should be prepared to be challenged about how the deviation from conventional practice in the field reflects what is customary in the field. Finally, the evaluator should be prepared to describe how not using psychological tests reflects the understanding of the current best practice, as well as the advantages of his or her data-gathering method in comparison with methods discussed in the literature.

Collateral interviews and record review. A critical data-gathering component is collateral data (Ackerman, 1995; Gould, 1998, 1999b; Grisso, 1986; Schutz et al., 1989; Shapiro, 1984; Stahl, 1994). Forensic evaluation differs from clinical evaluation in its emphasis on establishing historical truth

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(Greenberg & Shuman, 1997). Historical truth may be gleaned from, among other data sources, external information gained through interviewing people who know or knew the parent. This information may be explored for its veracity and possible contamination and is open to judicial scrutiny, for example, by direct examination and cross-examination. Collateral interviews are an important contribution to the overall picture of the parent’s behavior prior to legal involvement. They may provide information about the parent or parent-child relationship observations that is critical to the evaluation and otherwise unavailable to the examiner.

The evaluator needs to consider the interest or bias of a third party when determining the weight to be assigned to the corroborative information. Not all collateral interview sources provide the same material; nor is their information weighed in a similar manner. Information from a family member may provide a richer source of direct observational data but be confounded by the observer’s self-interest or bias derived from his or her relationship with the parent. On the other hand, collateral data from a soccer coach or school teacher are a weaker source of observation data yet less likely to be contaminated by the observer’s personal feelings about the parent.

The APA’s (1991,1994) and the AFCC’s guidelines and standards address the need for collateral interviews. Collateral data provide a means to increase the confidence of one’s conclusions because the obtained information comes from sources external to the investigation. These data can provide external validation in support of one or more hypotheses. Use of collateral information about parental competencies, parental behavior, and parental perception of the child is particularly important in light of recent research indicating that “parents of children involved in child custody disputes remain poor reporters. They tend to project their own disturbance and strong feeling” (Hysjulien, Wood, & Benjamin, 1994, p. 472).

Collateral interviews are a means of verifying hypotheses through independent sources. These third-party observations “can significantly reduce such problems in relevance and accuracy” (Heilbrun, 1992, p. 263). Melton et al. (1987) state that “probably the single best device (for determining accuracy) is corroboration through third party information” (p. 285). Collateral information is valuable because often the data, such as previous treatment records, are generated prior to the custody dispute. Thus, the data are less likely to be contaminated by the custody-driven agenda of one party.

Focusing solely on child custody evaluations, there appears to be a general consensus among published texts that collateral interview data and record reviews are critical components of a comprehensive child custody evaluation (e.g., Ackerman, 1995; AFCC, 1995; APA, 1991, 1994; Gould, 1998; Schutz et al., 1989; Skafte, 1985; Stahl, 1994).


In a child custody dispute, the parties are highly motivated to convince the examiner of their ability to be the better parent. There is also a strong motiva- tion to cast the other parent as a less competent parent (Rogers, 1998). There- fore, there is a significant probability that some &stortion of information will be presented to the examiner, either intentionally or unintentionally, by the parent. The examiner must take precautions to evaluate the degree and type of deception or malingering through third-party data (Rogers, 1997, 1998). Awareness of possible deception is also an important factor when examining children (Oldershaw & Bagby, 1997).

Professional records are an especially important means of verifying what the parties are or are not reporting about themselves or each other. Past therapy records are invaluable in examining what was important to this particular couple prior to the custody dispute. For example, where a party alleges substance abuse by the other party, the question is raised of whether substance abuse was discussed with the complaining party’s therapist prior to the custody dispute. An examination of medical and clinical records, including child abuse investigation records by a department of social services and law en- forcement, is extremely important in assessing child sexual abuse allegations.

We can think of no defensible position in which an evaluator does not engage in collateral interviews and/or records review when conducting a child custody evaluation.

Direct behavioral observations. A final area is direct observation of behavior. In cases of parental competency, custody determinations, and determinations of parental risks, parent-child interactions need to be observed (AFCC, 1995; APA, 1994; Schutz et al., 1989).

The “Guidelines” (APA, 1994) state that a comprehensive child custody evaluation “includes an evaluation of the interaction between each adult and child” (p. 678). The Model Standards (AFCC, 1995) also stress the need for an evaluation of each parent with each child, stating that “the children shall be observed with each parent or potential care taker in the office or home setting’’ (p. 4). A useful conceptual framework within which to organize behavioral observations involves the following: quality of the child’s interactions and behavior with each parent, communication and control patterns, behavior of the participants, and quality of interactions between and among caregivers.

We can think of no defensible position in which an evaluator does not directly observe parent-child interactions when conducting a child custody evaluation.

Gould, Stahl I CLlNlCAL AND FORENSIC MODEL 1NTEGRATION 407

THE COMPLEX ANSWER

We have outlined a scientific approach to conducting a child custody evaluation. We labeled it the simple answer because professional literature, tech- nology, research, and the tradition of forensic mental health speaks in one voice about the importance of placing a scientific framework on forensic mental health work products (Geyer, 1999).

The complex answer approaches the same question from a different perspective. The simple answer addressed the purpose of a child custody evaluation and was framed within the context of how the evaluation is conducted. The complex answer addresses the same question, but within the context of how the evaluation will be used.

It is this thorny question that has, in some academic arenas, polarized a necessary tension between two important, relevant aspects of the child custody process. Who among us would argue against finding the best possible information on which to base our recommendations? Who would argue against using research-based, psychometrically sound tools in measuring pertinent aspects of a parent’s behavior, a child’s behavior, or observational data drawn from a parent-child interaction? Who would argue that a good child custody evaluation also needs to meet the demands of the court and jurisdictionally specific criteria for admissibility?

The competent practitioner strives toward such important goals. Where the tension begins is in determining how to use the child custody evaluation. Is it written for the court as a means of assisting the trier of fact in making an informed decision about a particular family? Is it written for the parents as a means by which to assist in the process of settlement and family restructuring after divorce?

The polarized element of this debate has occurred because, just as in high-conflict postdivorce family systems, neither side took the time to seri- ously consider the arguments put forth by the other side or actively sought ways to integrate both perspectives into a comprehensive approach to child custody assessment.

Gould feels passionately about the need to craft an evaluation product within the legally defined rules guiding scientific evidence. However, he is also aware that his evaluations often are used to help families settle out of court and restructure their familial relationships in a more effective and conflict-free manner and that the dignity of the restructured family must be preserved.


Stahl feels passionately about the need to minimize litigation, support a family’s self-determination, help parents maintain their dignity, and encourage settlement opportunities, yet he is also aware that his evaluations are likely to be used in an adjudicative context and, as a result, must meet minimal levels of legal admissibility standards.

An artful child custody evaluation will help the family preserve and maintain dignity. All too often, we have reviewed colleagues’ reports in which they fall prey to the “he saidshe said” dynamic of parental tribal warfare. A competent evaluator knows that often, in the quest of litigation, one parent will attempt to make the other parent seem terrible. Like a mudslinging politi- cal campaign, each parent may be focused on the most derogatory aspects of the other’s behavior. It is important for the child custody evaluator to note the tribal warfare but not become part of it. The evaluator’s focus should be on the children and the family dynamics rather than taking sides in the familial dispute. In writing the report, the evaluator may need to describe each parent’s concerns and how that parent has engaged in tribal warfare against the other parent. However, it is important to remember that a parent’s story is subject to verification from alternative sources of data. Just because a story is compelling does not make it true. No matter how convincing or compelling the story is, a competent evaluator seeks alternative, external sources of information that help to clarify the familial dynamic in question. It is important to stay pri- marily focused on the children and their needs, as well as the manner in which each parent appears able and prepared to meet those needs.

Similarly, if a child custody evaluator uses psychological testing, it is important to report on the issues that directly relate to parenting, conflicts, and the children rather than some of the more negative personality features that often show up in psychological testing. The general consensus in the field is that a clinical diagnosis is unnecessary in most child custody evaluations. The diagnostic labels become weapons used by one side to injure the other parent rather than useful clinical descriptors. The evaluator needs to remember that parents and children will continue in their ongoing relationships long after the evaluation is over, and avoiding unnecessary negative information can help the restructured family continue in a more positive manner.

Whereas an important goal of the evaluation is to provide necessary information to the court to assist the judge in decision making, a secondary goal must be to assist the family in moving forward after the evaluation is com- pleted. Part of the art of performing child custody evaluations is to keep this goal in mind. By providing a thorough evaluation with sensible recommendations, staying focused on the children and their needs, and avoiding the temptation to join the “he saidshe said’ battle of the parents, the evaluator

Could, Stahl / CLINICAL AND FORENSIC MODEL INTEGRATION 409

can help many parents feel confident that a desirable solution for the family has been reached. Without becoming advocates of settlement, without switching roles and mediating a settlement, and without advocating for either parent, evaluators can thereby indirectly assist in efforts toward the settlement and encourage parents to reduce their litigation and conflict with one another. Although this may not be possible in some evaluations (particularly when one or both parents have a significant personality disorder, or in move-away evaluations), it is still important to keep this goal in mind while conducting and reporting on the evaluation.

Ultimately, the art of doing a complete child custody evaluation lies in the integration of the scientific method, a structured protocol, careful attention to all of the evaluation data, and careful application of the divorce research with one’s clinical judgment about the family dynamics, the child’s functioning and needs, and the ability of each parent to meet those needs. The art of performing a child custody evaluation also includes using the widest range of creativity in crafting one’s recommendations, especially in more difficult high-conflict situations or with very young children (e.g., see Kelly &Lamb, 2000 [this issue]). Rather than being a technician who gathers data and reports on it, the artful custody evaluator will be mindful of the family and encourage resolution of conflict, minimize unnecessary negatives, and ultimately refocus parents on their children.

The Forensic Mental Health Argument

A final area of discussion in our quest to integrate forensic mental health standards of evaluation with settlement-based models of child custody evaluation is to return to an examination of the professional ethics that guide us in our work. We begin with the ethical constraints governing current forensic mental health practice. The APA’s (1994) “Guidelines” provide an ethical framework within which a mental health professional may examine his or her professional practice behaviors against an emerging best-practice guideline. We know of no similar documents outlining ethical standards of professional practice guidelines for forensic mental health applied to child custody in the fields of social work or counseling.

A fundamental reason for mental health experts to become involved in child custody evaluations is to provide “an additional source of information and an additional perspective not otherwise readily available to the court on what appears to be in a child’s best interests, and thus can increase fairness [emphasis added] of the determination the court must make” (APA, 1994, p. 677). Mental health professionals bring the unique perspective of scientific

41 0 FAMILY AND CONCILIATION COURTS REVIEW

methods and procedures to the examination of the psychological best interests of the child. These methods and procedures have been developed over time and in a variety of forensic contexts. Forensic interview techniques, objective tests and self-report measures, collateral record review and interviews, and direct, systematic behavioral observations represent the best-practice criteria developed to date (Gould, 1999b).

For forensic mental health practitioners, understanding best-practice criteria is critical in the application of a mental health paradigm to child custody evaluations. According to the APA (1991, p. 657), “Forensic psychologists have an obligation to provide services in a manner consistent with the highest standards of their profession [emphasis added] .” A forensic work product that does not employ current, state-of-the-art forensic-scientific methods and procedures may provide the courts, and by extension the family involved in the custody dispute, incomplete, biased, or inaccurate information about the relevant questions needed to assist the family. This may result in decisions about the family that are based, in part, on scientifically indefensible conclusions and recommendations. Furthermore, these recommendations may be unable to meet admissibility standards or scientific scrutiny. We are not naive enough to pretend this does not happen, albeit inadvertently, on a daily basis in most jurisdictions throughout the country. Mental health professionals present clinical opinions and clinical reports to the court without knowing that there are professional practice standards in forensic mental health that should be applied to their work product. Judges are only recently becoming aware of the differences between clinical and forensic mental health roles (Greenberg & Shuman, 1997) applied to child custody evaluations (Ackennan & Kane, 1998; Gould, 1998).

It is one thing for unsuspecting but well-intentioned judges to allow as evidence clinical opinions that are believed by the mental health practitioner to be an admissible scientific work product but are in fact the data and the recommendations based on clinical rather than forensic standards.’ However, it is quite another to deliberately use a quasi-forensic methodology that, as an a priori assumption, deliberately excludes scientific methods and procedures that are precisely designed to both increase the reliability and validity of the gathered data and meet minimal standards of admissibility as scientific evidence (for a full discussion of these issues, see Goodman-Delahunty, 1997; Gould, 1998).

The scientific rigor of a comprehensive child custody evaluation is designed to provide the best possible data to the courts and meet minimal standards of scientific admissibility, and complement the professional role of the mental health evaluator in ensuring accuracy and fairness in the legal pro-

Gould, Stahl/ CLINICAL AND FORENSIC MODEL INTEGRATION 41 1

cess and compliance with both ethical standards and professional practice guidelines.

When using a child custody evaluation as a settlement-based tool, the evaluator needs to be aware of possible role conflicts. The purpose for a rig- idly defined boundary between clinical and forensic roles is to ensure that, to the degree possible, a forensic mental health professional who is appointed to conduct an independent, objective, and neutral evaluation maintains that position v is -h is the family throughout the course of his or her involvement in the evaluation process. Therefore, if the attorneys or other persons choose to use the evaluation report (as opposed to the evaluator) as a settlement tool, no ethical dilemma would be found in this practice. If the evaluator switches roles from that of a forensic examiner to a person involved in creating a settlement (such as amediator), it would be unethical within the boundaries of current ethical standards and professional practice guidelines.

If there is to be a future role for the evaluator as a settlement facilitator, then the first step needs to be the creation of a set of ethical principles that support such role diversity. It is unnecessary to change current ethical rules. There are other people who can mediate or facilitate a settlement conference aside from the evaluator. There is an inherent problem if settlement is not achieved and the case goes on to trial. If the evaluator changes roles for the settlement conference, what role does the evaluator play at trial? The examiner has been privy to behavior by each parent during the settlement conference that may affect how the examiner thinks about each parent. How does the evaluator testify only about the information from the evaluation and not include opinions drawn from the settlement conference?

Alternatively, what happens if the parties agree to allow the evaluator to participate in the settlement conference and also to testify at trial, if the need arises? How does the evaluator determine the meaning of each parent’s behavior, within the context of the settlement conference, when each parent knew ahead of time that the evaluator may ultimately testify? How does the evaluator’s presence and the parent’s knowledge that the evaluator may testify change each parent’s behavior during the settlement conference? Does the evaluator’s participation in the settlement conference increase or decrease parental compliance during the settlement conference? How does it increase or decrease the chances of settlement?

Finally, the evaluator may obtain information during the settlement conference about parents and their relationships outside the scope of the custody evaluation process. Which information should the evaluator be allowed to use and which should the evaluator be asked to discard? This should raise significant concerns for the forensic mental health practitioner who is ethically


obliged to “understand the civil rights of parties in a legal proceeding in which they participate, and manage their professional conduct in a manner that does not diminish or threaten those rights” (APA, 199 1, p. 658). We sub- mit that changing roles, as well as the use of anything other than the best-practice recommendations for forensic scientific evaluations, may intentionally or otherwise diminish or threaten the civil rights of parties to a legal dispute. This occurs precisely because the data provided to the court are less comprehensive, less rigorously obtained, and result in interpretations and recommendations that are known to be incomplete and potentially invalid at the time the court accepts them as testimony.

CONCLUSION

Throughout this article, we have focused on the moral, ethical, scientific, and clinical aspects of child custody evaluations. There is a need to stay current with the behavioral science literature in all areas related to child custody evaluation, including but not limited to child development, adult psychopathology, children’s adjustment to separation and divorce, forensic use of psychological tests, forensic ethics, and forensic methods and procedures applied to custodial evaluation. We also need to maintain contact with colleagues, within our locale as well as through professional memberships, who continually challenge our beliefs and biases. Each child custody evaluator should strive to find his or her own balance of blending these facets. Because evaluators work in a psycholegal setting, they need to be prepared to explain and defend their beliefs, the data they gather, how they gather them, and how they have integrated their beliefs and the data when formulating their ulti- mate opinions and conclusions. Evaluators need to stay humble, inform families and the court about what they do and do not know, and recognize the possible fallibility of their work. Finally, child custody evaluators are continually refining and reinventing their work. They strive to find a balance between the art and science of their work, which will best serve those people they so passionately wish to serve: the precious children and their families caught in this whirlwind of uncertainty and confusion called divorce.

NOTE

1. A discussion of this critical distinction is beyond the scope of this article. The reader is referred to Gould (1998) for an extensive discussion of the issue.

Gould. Stahl I CLINICAL AND FORENSIC MODEL INTEGRATION 413

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Jonathan W Gould is a practicing forensic and clinicalpsychologist in Charlotte, North Carolina. His most recent book is Conducting Scientifically Crafted Chdd Custody Eval- uations (Sage, 1998).

Philip M . Stahl is the chair ofthe Association of Family and Conciliation Courts’s Child Custody Evaluation Committee and a psychologist in private practice in Dublin, Cali- fornia. where he specializes in custody evaluations. His most recent books are Complex Issues in Child Custody Evaluations (Sage, I999) and Parenting After Divorce (Impact, in press).

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THE ART AND SCIENCE OF CHILD CUSTODY EVALUATIONS

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