National Coalition Against Parental Alienation

Promoting Awareness and Solutionssm

In re Marriage of Finer:

Alienating Parent: ♀ — Custody to target parent: ♂

“Here, in its lengthy permanent orders, the trial court initially recognized that one of the issues presented to it was a ‘[d]etermination of what is in the best interest of the minor child pursuant to C.R.S. § 14-10-124.’ It then made numerous findings relating to the statutorily relevant factors. The court found, inter alia, that wife was unable to read her child’s needs accurately; that while wife had tended to alienate her daughter from husband; and . . .that husband could, more so than wife, allow the child to develop her own personality and needs separate from husband’s needs.”
In re Marriage of Finer, 920 P.2d 325, 327-28 (Colo.App. 1996).

L.A.G. v. People in Interest of A.A.G:

Alienating Parent: ♀ — Custody to target parent: ♂

“The juvenile court stated that its finding that the mother was not encouraging visitation with the father or a relationship between the children and the father was based on the fact that the mother had twice been held in contempt of court for failing to encourage visits between the father and the children and on one expert witness’ testimony that the children had become alienated from their father due to the mother’s anger and bitterness toward the father.”
L.A.G. v. People in Interest of A.A.G., 912 P.2d 1385, 1388 (Colo. 1996).

In re Marriage of Monteil:

Alienating Parent: ♀ — Custody to target parent: ♂

“[T]he trial court found with record support that the partied has moved numerous times during the marriage and that mother’s mental and physical health negatively impacted her ability to parent the children. It also found most important the evidence which established inappropriate and excessive parental alienation by mother.”
In re Marriage of Monteil, 960 P.2d 717, 719 (Colo.App. 1998).

Kniskern v. Kniskern:

Alienating Parent: ♀ — Custody to target parent: ♂

“The trial court found that mother continued to engage in parental alienation. Accordingly, the court determined that pursuant to the parties’ court-approved agreement, the children were to reside with father in New York.”
Kniskern v. Kniskern, 80 P.3d 939, 940 (Colo.App. 2003).

In re Marriage of Hatton:

Alienating Parent: ♀ — Custody to target parent: ♂

“[Mother] appeals from post-dissolution of marriage order awarding all parenting time and decisionmaking responsibility to [father] and allowing mother no contact with the children except with father’s written permission.] . . .After concluding his investigation, the evaluator found that mother had a ‘seriously impaired capacity for reality testing’ and met the diagnostic criteria for a ‘Delusional Disorder of a persecutory (nonbizarre) type’; that the two older children had become enmeshed in mother’s battle against father; that the children were not credible reporters because they were colluding with mother to generate false allegations against father; and that the extent of mother’s enmeshment and role reversal with the two older children constituted a form of emotional child abuse. The evaluator found that the oldest child was following mother’s lead in applying pressure to her younger siblings to alienate them from father. He concluded that mother represented a ‘real and immediate risk’ to the children, and that the oldest child represented a real and immediate risk to the younger children. . . . [I]n an extensive, longitudinal study in Colorado, parental alienation has been found to occur in twenty percent of cases involving custody and parenting time. . . . Here, the trial court was entitled to rely on the findings of the parental evaluator that mother was suffering from a delusional disorder and that the two older children had been enmeshed in mother’s battle against father, among other findings. [Order reversed to the extent it denies mother all contact with the children and to the extent it allows mother to have parenting time only with father’s consent, remanded for further proceedings consistent with the opinion; otherwise affirmed in all other respects.]”
In re Marriage of Hatton, 160 P.3d 326, 331, 334 (Colo.App. 2007) (citing Leona M. Kopetski, “Identifying Cases of Parent Alienation Syndrome—Part I,” 27 Colo. Law. 65, 68 (Feb.1998)).

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