National Coalition Against Parental Alienation

Promoting Awareness and Solutionssm

Vincent M.C. v. Mary T.C.:

[UNPUBLISHED]

Alienating Parent: ♀ — Custody to target parent: ♂

“Dr. Orlov . . . testified as to two factors at work in this family. First, she believes that parent alienation syndrome is a factor . . . that Mother has strong feelings against Father and his mother, and over time these feelings have extended to Father’s friends and family. Mother’s feelings from the basis of her determination to take the children away from Father and his family in any way she can, including the use of false allegations of physical and sexual abuse.”
Vincent M.C. v. Mary T.C., 1998 WL 420756 at * (Del.Fam.Ct.).

Asher v. Asher:

[UNPUBLISHED]

Alienating Parent: ♂ — Custody to target parent: ♀

“Dr. Orlov believes that Father is using the fact that Robbie and Anthony have always been very close in order to alienate Robbie from Mother.”
Asher v. Asher, 1999 WL 33100154 at *4 (Del.Fam.Ct.)

Cynthia D. v. Jimmy D.:

[UNPUBLISHED]

Alienating Parent: ♂

“Besides Dr. Orlov’s concern that Mother is overanxious about the child, she is concerned that, because of the negative attitude of Mother and her family towards Father, there are signs that parental alienation could develop in the child of there are extensive contact with Mother. Dr. Orlov fears that Mother’s anxiety could lead the child to be hypochondrial and to have separation
problems when he has to go to school.”
Cynthia D. v. Jimmy D., 1999 WL 1473684 at *4 (Del.Fam.Ct.).

R.L. v. J.L.:

[UNPUBLISHED]

Alienating Parent: ♀ — Custody to target parent: ♂

“The Court finds Dr. Romirowsky’s interviews of A and B to be the most probative. In regards to B he concluded that she appeared to be very ambivalent about the kind of relationship she wants to have with Mother. It is obvious that she feels caught in the middle between Mother and Father, and she doesn’t want to take sides. However, he concluded that she has ambivalence towards Mother, but not with Father. He said that she appeared to be more affectionate and clingy with Father. He found no evidence of any parental alienation by either parent attributing to her distress.”
R.L. v. J.L., 1999 WL 33100145 at * (Del.Fam.Ct.).

Ford v. Ford:

[UNPUBLISHED]

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

“The Court notes Dr. Gardner did not find parent alienation in this case. He testified that generally he only recommends transferring custody to parents in very moderate and severe parent alienation cases. He indicated that there are very few cases involving false accusations that are not accompanied by parent alienation syndrome. This harks back to the Court’s earlier finding that if Mother were seeking revenge on Father, she would have taken a more negative approach in influencing Susan.”
Ford v. Ford, 2000 WL 33200935 at *7 (Del.Fam.Ct.).

Barton v. Carter:

[UNPUBLISHED]

Alienating Parent: ♀

“On the subject of Mother’s undue influence over the children, Dr. Romirowsky testified as follows: ‘Unfortunately, there is an issue here, I think, an issue of parent alienation. There is no question in my mind but that the children’s attitude pertaining to Father has been strongly influenced by things that they have been actually taught by Mother about the Father’s disposition, about Father’s discipline, about Father’s alleged anger, about Father’s alleged abuses.”
Barton v. Carter, 826 A.2d 298, 2003 WL 21364494 at *2 (Del.Super.).

D.C. v. K.A.B.:

[UNPUBLISHED]

Alienating Parent: ♀

“Pursuant to the October 22, 2002 Order, which was appealed by Mother, but affirmed by the Supreme Court on Appeal, the Court made a determination that Mother was alienating Father’s relationship with the minor children. Her recent acts corroborate her continued alienation of Father and fall in the category of criminal interference of custody. Since she has obviously crossed state lines, initially in Indiana and now in various other states, Kentucky being alleged as one, that criminal act arises to the level of Felony.”
D.C. v. K.A.B., 2003 WL 23269522 at *3 (Del.Fam.Ct.).

S.A.G. v. J.M.G.:

[UNPUBLISHED]

Alienating Parent: ♀

“There was no evidence of any mental or physical health issues which are significant except for the issues of J’s asthma and the parental alienation against Father, which is noted in this Opinion. The parental alienation issue, however, is significant in reference to D and N and favors strongly an arrangement whereby Father would have primary residence during the school year if Mother chooses to remain in Arizona.”
S.A.G. v. J.M.G., 2004 WL 1146596 at *3 (Del.Fam.Ct.).

T.C.C. v. M.L.C.:

[UNPUBLISHED]

Alienating Parent: ♀

“The Court also notes Mother’s frequent attempts at parent alienation, which include the Criminal No Contact Order and refusal to visit at the Hudson Center, which led to no visitation between Father and the children for four months. In addition, this Court notes the DFS testimony that Mother tended to file these and similar charges right before scheduled court hearings. These actions speak to Mother’s credibility, which was a significant consideration for the Court in reviewing the testimony of the parties.”
T.C.C. v. M.L.C., 2004 WL 3245937 at *6 (Del.Fam.Ct.).

D.M.W. v. T.V.W.:

[UNPUBLISHED]

Notes: Joint legal custody continued. The expert evaluated for parental alienation and testified but found no evidence to support parental alienation.

“Dr. Pedro Ferreira’s was contacted about this case by Mother’s counsel on the morning of December 3, 2004. He did not perform a custody evaluation. Dr. Ferreira reviewed Dr. Romirowsky’s file and acknowledged that he could not read all of Dr. Romirowsky’s handwriting. Dr. Ferreira testified generally regarding parental alienation of a 7 to 9 year old and stated that there is a range of parental alienation syndrome. A child who is experiencing parental alienation would show an ‘unwillingness or anxiety or fear to [participate in] activities with [the alienated] parent.’ In order to determine if there was parental alienation, a professional should spend time with the child and meet with the child’s teacher or daycare provider in order to learn what comments the child has made.”
D.M.W. v. T.V.W., 2005 WL 3557436 at *6 (Del.Fam.Ct. 2005).

E.A.R. v. K.N.D.:

[UNPUBLISHED]

Alienating Parent: ♀ — Custody to target parent: ♂, then joint, then to alienator

“Pursuant to the Court’s Order of July 25, 2005, Father was awarded sole custody of the two children with primary residence based upon the best interest factors, Mother’s parent alienation, and her failure to appear at the hearing.”
E.A.R. v. K.N.D., 2006 WL 4041933 at *1 (Del.Fam.Ct.).

J.C.H. v. E.H.:

[UNPUBLISHED]

Alienating Parent: ♀

“The Court is troubled by Mother’s apparent attempt to alienate G from Father. As stated in this Court’s June 4, 2007 Order, five DFS complaints were either not accepted for investigation or found to be unsubstantiated. Mother filed a seven-page PFA petition and, after a hearing, this Court found by a preponderance of the evidence that abuse had not occurred. Mother then raised some of the same issues in her New York petition and that petition was ultimately withdrawn. Although the New York child protective services concluded that maltreatment was ‘indicated,’ Mr. L candidly admitted that there was no evidence that the marks that he saw on G were inflicted by Father. It also concerned Mr. L, as it does this Court, that there was a four-day gap before these marks were reported and, when he saw them, the bruises were healing.”
J.C.H. v. E.H., 2007 WL 5158175 at *9 (Del.Fam.Ct.).

A.S. v. J.S.:

[UNPUBLISHED]

Alienating Parent: ♀ — Custody to target parent: ♂

“As noted below, both parents have been fairly compliant with prior orders of the Court concerning custody and visitation, aside from the three weeks that Mother alienated the child and prevented him from seeing his Father.”
A.S. v. J.S., 2008 WL 1953463 at *1 (Del.Fam.Ct.).

S.R.W. v. J.F.Z.:

[UNPUBLISHED]

Alienating Parent: ♀

“Based on the above findings regarding Mother’s attempts to alienate E from Father, the Court finds that allowing Mother to have unsupervised contact with E at this time would ‘significantly impair [E’s] emotional development.’”
S.R.W. v. J.F.Z., 2011 WL 5831755 at *26 (Del.Fam.Ct. 2011).

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