National Coalition Against Parental Alienation

Promoting Awareness and Solutionssm

In Interest of T.M.W.:

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

“During the final hearing the trial court heard considerable testimony, including that of Harry Krop, Ph.D., a forensic psychologist, and respondent had deposed both the child and her mother. Dr. Krop had been asked by counsel for the respondent father to consult with respondent to determine whether the relationship between the child and the father could be restored. Dr. Krop suggested that a ‘parental alienation syndrome’ may be present in this case and recommended that he, or another qualified expert, examine the child for the purpose of exploring that syndrome. The trial court entered an order granting the psychological examination of the child, finding that further expert guidance and assistance is essential in order to resolve the issues presented in this case.”
In Interest of T.M.W., 553 So.2d 260, 261, 14 Fla. L. Weekly 2733 (Fla.App. 1 Dist. 1989).

Blosser v. Blosser:

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

“The final report of the psychologist who had tested and interviewed the parties was stipulated into evidence. Dr. Lynn Berstein concluded that the parties had no significant psychological problems although she recommended family therapy for problem solving regarding the custody/visitation litigation stress, a ‘Phase of Life’ problem. The child did not exhibit any parental alien-
ation syndrome which is sometimes seen with children who are shunted between separated parents in divorce situations.”
Blosser v. Blosser, 707 So.2d 788, 780 (Fla.App. 2 Dist. 1998).

Scaringe v. Herrick:

Alienating Parent: ♂ — Custody to target parent: ♀

“The trial court found the father to have denied or unilaterally reduced the mother’s visitation when the father had custody. The trial court coupled this finding with an additional finding of ‘alienation by the father-primary residential parent to the extent that the child ‘hated’ the mother.’ Such a finding is a valid basis for a change in custody. See Berlin v. Berlin, 386 So.2d 577 (Fla. 3d DCA 1980). This case turned on credibility determinations, and we cannot say the trial court abused its discretion in granting the petition to modify custody.”
Scaringe v. Herrick, 711 So.2d 204 (Fla.App. 2 Dist. 1998).

Perlow v. Berg-Perlow:

Alienating Parent: ♂ — Custody to target parent: ♀

“[A]ppellant contends that the trial court erred in allowing expert testimony regarding Parental Alienation Syndrome, because the testimony did not meet the standards of Frye. . . Appellant failed to make this argument before the expert testified, therefore the point is waived for review.”
Perlow v. Berg-Perlow, 816 So.2d 210, 215 (Fla.App. 4 Dist. 2002).

Marquard v. Secretary for Dept. of Corrections:

Alienating Parent: ♂♀

“Dr. Krop . . . described how each of Marquard’s parents alienated Marquard from the other parent: [‘]After talking to the mother and father, it became clear that there were a behavior pattern on both of their parts which we now refer to as Parental Alienation Syndrome. It’s essentially when one parent, usually the custodial parent, does things or says things to the child or in front of the child which attempts, either consciously or unconsciously, to alienate the child from the other parent. At that time period, I don’t believe there was terminology for that; but it’s been a fairly common phenomenon for several years.[’]”
Marquard v. Secretary for Dept. of Corrections, 429 F.3d 1278, 1286 (11th Cir. Fla. 2005).

Wade v. Hirschman:

Alienating Parent: ♀ — Custody to target parent: ♂

“The trial court in Wade concluded that there were substantial and material changes in circumstances, and its findings are supported by competent, substantial evidence, including: evidence of parental alienation of the Father by the Mother; failure of the Mother to cooperate with the parenting coordinator and comply with the parenting agreement; violation of shared parental responsibility as evidenced by the Mother’s unilateral change of the child’s elementary school and her unilateral change of the child’s therapist; and the finding that the Mother was in contempt of court for her actions relative to visitation. The trial court . . . found that it was in the best interest of the child for the parties to be awarded shared parental responsibility with the Father as the primary residential parent. We cannot find that the trial court abused its discretion in modifying the custody agreement [from split rotating custody to primary residence with the ex-husband]. Thus, we agree with the trial court’s decision.”
Wade v. Hirschman, 903 So.2d 928, 935 (Fla. 2005).

Schumaker v. Schumaker:

Alienating Parent: ♂

“[T]he court made the following determination that it has . . . [g]rave concerns as to whether shared parental responsibility would be detrimental to the children in light of the Father’s parental alienation, but the court wants to give the Father a chance to ‘clean up his act,’ cease parental alienation and promote the Mother in the eyes of the children.”
Schumaker v. Schumaker, 931 So.2d 271, 275 (Fla.App. 5 Dist. 2006).

Lovell v. Lovell:

Alienating Parent: ♂

“The experts testifying on behalf of each of the parties noted, on the other hand, that the new wife had never harmed the children, and that the young man’s weight loss stemmed either from a severe case of parental alienation (in the view of one expert), or from ‘anxiety related issues’ (in the view of the other).”
Lovell v. Lovell, 14 So.3d 1111, 1114 (Fla.App. 5 Dist. 2009).

Grigsby v. Grigsby:

Alienating Parent: ♀ — Custody to target parent: ♂

“The court characterized the Mother’s actions as the worst case of parental alienation that it had ever seen. Based on the Mother’s egregious behavior, the trial court assigned sole parental responsibility for all four children to the Father and completely suspended the Mother’s time-sharing with the children.”
Grigsby v. Grigsby, 39 So.3d 453, 456 (Fla.App. 2 Dist. 2010).

L.W. v. Department of Children and Families:

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

“A psychologist and forensic examiner explained that the child was exposed to parental estrangement rather than parental alienation. Parental estrangement is a child’s healthy adaptive response to trauma, as opposed to parental alienation, which occurs when one parent provides erroneous information to the child resulting in unwarranted rejection of the other parent.”
L.W. v. Department of Children and Families, 71 So.3d 221, 223 (Fla.App. 4 Dist. 2011).

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