National Coalition Against Parental Alienation

Promoting Awareness and Solutionssm

In re John W.:

Alienating Parent: ♀ — Custody to target parent: ♂

“Dr. Chambers concluded that no child abuse occurred. He blamed the mother for inducing the child to make statements indicating abuse. Chambers wrote, ‘[t]he allegations are a result of a subtle Parental Alienation Syndrome directed, at an unconscious level, by the minor’s mother. . . .” However, Dr. Chambers also concluded that Michelle was sincere in her belief that the allegations occurred.”
In re John W., 41 Cal.App.4th 961, 48 Cal.Rptr.2d 899, 96 Cal. Daily Op.
Serv. 205, 96 Daily Journal D.A.R. 283 (Cal.App. 4 Dist. 1996).

In re Marriage of Brooker:

[UNPUBLISHED]

Alienating Parent: ♀

“Dr. Rick found that wife had used excessive punishment (discipline) with Alexander on occasion, spoke negatively about husband to the child, and caused the child to be alienated from his father. In contrast, not a single person interviewed by Dr. Rick had anything negative to say about husband.”
In re Marriage of Brooker, 2001 WL 1219499 at *1 (Cal.App. 2 Dist.).

Wilson v. Shea:

Alienating Parent: ♀

“In a motion to vacate the judgment heard before the formal order was signed, . . . Robin argued, among other things, that the judge had not properly articulated findings in support of $150 to be subtracted from the guideline amount. The judge responded: ‘The findings are not obvious? Mother had basically alienated the relationship between father and daughter.’ The point of the deduction, the judge explained, was to attempt ‘everything we could to keep father involved in this child’s life.’”
Wilson v. Shea, 87 Cal.App.4th 887, 104 Cal.Rptr.2d 880 (Cal.App.4.Dist. 2001).

In re Hans M.:

[UNPUBLISHED]

Notes: Alienating parent unknown, expert evaluation pending.

“One of the experts who testified at trial stated Hans and Nils may have been suffering from what he described as ‘parental alienation.’ That term describes a ‘a particular pattern with families that are in litigation around custody kind of issues. It proposes that one parent has brainwashed or programmed their child or their children to be mean, nasty, [and] unforgiving towards the other parent.’ The court said it intended to appoint an independent expert to determine whether Hans and Nils were in fact suffering from parental alienation syndrome.”
In re Hans M., 2002 WL 1978965 at *11 (Cal.App. 1 Dist.).

Nancy P. v. Superior Court:

[UNPUBLISHED]

Alienating Parent: ♀

“The court found the mother had not complied with her case plan because she pressured the boys to choose living with her and this finding constituted prima facie evidence of detriment to return the boys to her. Accordingly, the court placed the children with the father with family maintenance services. ‘What is very troubling and is of great concern to the court is the change in the children’s testimony the court observed.’ And the rational inference the court is making, coupled with the statements that were made in the report of the social worker, is that mother has engaged in practices that go to the question of emotionally pressuring and manipulating these children to develop an alienation against their father.”
Nancy P. v. Superior Court, 2002 WL 462731 at *3 (Cal.App. 4 Dist. 2002).

In re Marriage of Arthur:

Alienating Parent: ♀ — Custody to target parent: ♂

“Jacquelyn’s contentions regarding parental alienation stem from Barr’s statement in her declaration in support of the motion to modify that ‘[t]he trial court found that [Jacquelyn] has emotionally aligned the children with her and against [Gerald]. The situation has not improved and in fact, has become worse.’ Jacquelyn contends that these findings are pending on appeal and
therefore inappropriate to use, that Barr is unqualified to make a psychological diagnosis, and that ‘parental alienation syndrome’ fails to meet the standards for admissibility of scientific evidence. We disagree. . . . Here, the trial judge (Judge Ullman) had also made the final custody order that Barr sought to modify. A copy of Judge Ullman’s entire ruling on that final order, including what he had found regarding any emotional alignment, was made a part of the record of the modification motion. Consequently, the trial judge at the modification proceedings was well aware of his previous findings and how he had weighed evidence of parental alienation.”
In re Marriage of Arthur, 2004 WL 1732709 at *9 (Cal.App. 3 Dist. 2004).

In re J.W.:

[UNPUBLISHED]

Notes: Custodial parent did not change. The expert evaluated for parental alienation and testified but found no evidence to support parental alienation.

“Dr. Viera Pablant, a clinical psychologist, began seeing the children in a therapeutic setting in December 2000. She was still seeing the girls in November 2003, when the contested hearing began. The court qualified her as an expert in the areas of child psychology, child development, child sexual abuse, families in high conflict divorces, and parental alienation.”
In re J.W., 2005 WL 1028251 at *8 (Cal.App. 6 Dist.).

In re Marriage of Sukel v. Johnson:

[UNPUBLISHED]

Alienating Parent: ♀

“The court also ordered the parties to meet and ‘fully cooperate’ with Dr. William Dess on the issue of whether Mother’s conduct was causing Katherine to become alienated from Father. . . . In August 2003, Dr. Dess prepared a lengthy report discussing his findings based on his meeting with Mother and Father and his review of prior reports.”
In re Marriage of Sukel v. Johnson, 2005 WL 1523951 at *2 (Cal.App. 4 Dist.).

In re Mac. S.:

[UNPUBLISHED]

Alienating Parent: ♀ — Alienating parent lost in Illinois and filed for relief in California. California court refers to Illinois and custody to target parent: ♂

“[California decision recounts the custody trial in Illinois, in which the Illinois family law court states as follows:] Pursuant to Dr. Owley’s report and the testimony of Dr. Shapiro . . . there are question[s] as to [mother’s] mental condition. The [Illinois family law] court finds that all of [mother’s] allegations as to abuse are unfounded. Unfounded allegations of sexual abuse made by one parent can be grounds for granting custody to the other parent. [Citation.] The court finds that [father] provides a greater willingness and ability to facilitate and encourage a close and continuing relationship between the non-custodial parent. Further[,] based upon the reports of Dr. Shapiro and Dr. Owley, [mother’s] conduct is a form of parental alienation towards [father]. . . . We deny mother’s petition for [extraordinary] writ relief [alleging abuse]. The juvenile court’s April 22, 2005 and January 20, 2006 orders are affirmed. The case is remanded to the California juvenile court for proceedings to immediately effectuate transport of Mac and Lynn to the State of Illinois. . . . Once the children are returned to Illinois, the California juvenile court shall dismiss the case. . . . Mother and the paternal grandparents are ordered not to interfere with the California juvenile court’s jurisdiction over the children. Mother and the paternal grandparents are ordered not to interfere with the immediate return of the children to the State of Illinois.”
In re Mac. S., 2006 WL 2258028 at **5, 27-28 (Cal.App. 2 Dist.).

In re Victoria R.:

[UNPUBLISHED]

Alienating Parent: ♀

“June 24, 2004, the Solano County Family Court awarded primary physical custody of the girls to Father. Mother notified the Solano family court of the San Bernardino County Juvenile Court’s order. In response, the family court wrote in the custody order: ‘The court has carefully considered the findings of the juvenile court, whose jurisdiction is now terminated, and upon the evi-
dence presented in trial and the other documents and pleadings in the file, finds that the orders contained herein are in the best interests of the children. The court further finds that these orders are essential to preclude [M]other’s extreme alienation of the children [and] necessary if Father and children are to be allowed to have a relationship.’”
In re Victoria R., 2006 WL 864529 at *2 (Cal.App. 4 Dist.).

In re Troy B.:

[UNPUBLISHED]

Alienating Parent: ♀

“Dr. Korn reported Nancy B. lacked insight into her behavior and had engaged in instances during the sessions of parental alienation by encouraging Troy B. to talk about what David D. had done to him. Based on his interaction with her, Dr. Korn provisionally diagnosed Nancy B. as bi-polar, manic with paranoid features.”
In re Troy B., 2007 WL 2660236 at *3 (Cal.App. 2 Dist.).

In re Marriage of Lampe:

[UNPUBLISHED]

Alienating Parent: ♀

“The bulk of the testimony at trial did focus on the validity of Tamara’s allegations of sexual abuse. The court, however, also heard testimony from a court appointed expert, Dr. Bernstein. He was ‘appointed as an independent Family Assessor, . . . to among other issues assess any indication of the presence of Munchausen’s Syndrome by Proxy, the possibility of molest and the possibility of parental alienation of either parent.’ He understood he was to perform a psychological evaluation of the parents and to assist in determining a suitable parenting plan. He gave two psychological tests to each parent and testified extensively regarding the results.”
In re Marriage of Lampe, 2008 WL 3877773 at *5 (Cal.App. 5 Dist.).

In re T.B.:

[UNPUBLISHED]

Alienating Parent: ♀

“At the conclusion of the adjudication, the court stated: [T]he court agrees with counsel for the father and the [Department] that this is a very serious case of parental alienation.”
In re T.B., 2008 WL 4793234 at *4 (Cal.App. 2 Dist.).

Carias v. Delgado:

[UNPUBLISHED]

Alienating Parent: ♀ — Court Specifically addressed “Play Therapy”

“Dr. Brodie expressed concern over the way the child was being psychiatrically treated by Head, indicating concern with the use of play to vilify father and the alienation of him as a parent.”
Carias v. Delgado, 2009 WL 2622847 at *4 (Cal.App. 4 Dist.).

In re Marriage of J.H. and Y.A.:

[UNPUBLISHED]

Alienating Parent: ♀ — Custody to target parent: ♂

“The attempts to vilify Father include numerous allegations of spousal and child abuse, which Dr. Wu and others have found unsubstantiated and unfounded. Dr. Wu also noted that Mother said things to Jonathan to alienate him from Father.”
In re Marriage of J.H. and Y.A., 2009 WL 2106145 at *3 (Cal.App. 1 Dist.).

In re Marriage of Payton and Ledbetter-Payton:

[UNPUBLISHED]

Alienating Parent: ♀

“The court found that while ‘there is a history between the father and son, . . . currently there is also either by design or just emotional, . . . there is parental alienation toward father that is being induced by the environment that the child is currently in, which is mother.’”
In re Marriage of Payton and Ledbetter-Payton, 2009 WL 2187745 at *6 (Cal.App. 3 Dist.).

In re Marriage of Elgammal and Aboutaleb:

[UNPUBLISHED]

Alienating Parent: ♂ — Custody to target parent: ♀

“The court found Aboutaleb ‘illegally removed from the Court’s file the Dissomaster used by Judge Juhas in support of his award of Child and Spousal Support.’ In addition, Aboutaleb ‘engaged in a clear pattern of parental alienation and willfully violated this Court’s Orders in an effort to interfere with and thwart [Elgammal’s] relationship with and custody of the Minor Child.’ Aboutaleb ‘willfully fabricated evidence’; ‘willfully attempted to suborn perjury; specifically by threatening the minor child, Sandra, with physical injury and death if she did not make false allegations against [Elgammal] and her sons of inappropriate sexual conduct’; and ‘willfully made false representations to the Court in an effort to delay and obstruct the processes of the Court.’”
In re Marriage of Elgammal and Aboutaleb, 2010 WL 4970224 at * (Cal.App. 2 Dist.).

In re Marriage of Nair [I]:

[UNPUBLISHED]

Alienating Parent: ♂

“Father’s support obligation was based on the trial court’s finding that ‘to the extent mother is not exercising her 50% parenting time with the older child, this is due solely to father’s misconduct in alienating the older child from his mother and failing to take all necessary steps to reunify the older child with his mother consistent with the [ sic ] all parenting orders in effect.’”
In re Marriage of Nair [I], 2010 WL 780882 at *3 (Cal.App. 3 Dist.).

In re Marriage of Nair [II]:

[UNPUBLISHED]

Alienating Parent: ♂

“The trial court prefaced its ruling on the restraining order against father by noting: ‘Unfortunately, these children are caught between two adults and the adults have not done a good job of keeping the kids out of it. And now it’s left to the courts to step in and act as surrogate parents where the parents have, for whatever reason, not been able to deal with that problem. And that’s regrettable. . . . [T]he alienation from the mother, I feel has been established.’”
In re Marriage of Nair, 2010 WL 2330204 at **10-11 (Cal.App. 3 Dist.).

In re Marriage of Yassin and Aboutaleb:

[UNPUBLISHED]

Alienating Parent: ♂ — Custody and fees awarded to target parent: ♀

“The fee award was imposed specifically as a sanction against Aboutaleb based upon the trial court’s finding that he ‘engaged in a clear pattern of parental alienation and willfully violated this Court’s Orders in an effort to interfere with and thwart [Yassin’s] relationship with and custody of [Mariem].’”
In re Marriage of Yassin and Aboutaleb, 2010 WL 4970285 at *5 (Cal.App. 2 Dist. 2010).

In re J.R.:

[UNPUBLISHED]

Alienating Parent: ♀

“[I]n contrast to mother—who actively engaged in a campaign designed to alienate J.R. from his father—there is no evidence father shared information or discussed with J.R. any matters regarding interpersonal conflicts he has had with mother, or the disruption to his visitation caused when she obtained an unnecessary restraining order against him.”
In re J.R., 2011 WL 6015706 at *4 (Cal.App. 2 Dist.).

In re Y.L.:

[UNPUBLISHED]

Alienating Parent: ♀

“As Burgan testified, the present case included all the elements of parental alienation. Thus, the evidence supported the juvenile court’s finding that the children’s extreme anxiety and fear of their father was the result of the mother’s conduct.”
In re Y.L., 2011 WL 5138642 at *11 (Cal.App. 6 Dist.).

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