National Coalition Against Parental Alienation

Promoting Awareness and Solutionssm

White v. White:

Alienating Parent: ♀ — Custody to target parent: ♂

“Dr. Lawlor testified at trial that it would be in the best interest of the children for the trial court to award sole custody to Daniel because Sandy was engaging in a pattern of behavior known as parental alienation syndrome.”
White v. White, 655 N.E.2d 523, 526 (Ind.App. 1995).

Hanson v. Spolnik:

Alienating Parent: ♀ — Custody to target parent: ♂

“Dr. Richard Lawlor, a child psychologist, who, after reviewing records and reports from Child Protective Services, Michelle Crane and several other counselors, indicated that Marianne had not taken appropriate action in resolving the incident between M.S. and A.L. He also indicated that Marianne’s comments and allegations against Edward were directed at alienating M.S. from Edward and that Marianne’s behavior endangered M.S.’s emotional and psychological development.”
Hanson v. Spolnik, 685 N.E.2d 71, 76 (Ind.App. 1997).

In re Paternity of V.A.M.C.:

Alienating Parent: ♂ — Custody to target parent: ♀

“Father challenges the portion of Finding 11 that provides: ‘The Court specifically declines to find Dr. Watson’s recommendations were based on a diagnosis of Parental Alienation Syndrome.’ [E]ven if Father is correct that Dr. Watson based her recommendation upon PAS, there is a difference between basing a recommendation upon a theory and making a diagnosis of a syndrome. In fact, the very testimony that Father cites indicates that Dr. Watson had not diagnosed PAS, because Dr. Watson testified that there was a ‘risk of’ parental alienation in the future. Consequently, when we view the evidence in the light most favorable to the Finding, the challenged sentence in the trial court’s Finding 11 is not clearly erroneous.”
In re Paternity of V.A.M.C., 768 N.E.2d 990, 998-99 (Ind.App. 2002).

Kirk v. Kirk:

Alienating Parent: ♀ — Custody to target parent: ♂

“In April 1998, Ruff diagnosed G.L.K. with parental alienation syndrome and again recommended ‘that the court consider removing [G.L.K.] to a more neutral setting so that she can have the opportunity to form her own, independent views of her father without any potential interference or alienation.’”
Kirk v. Kirk, 759 N.E.2d 265, 268 (Ind.App. 2002).

In re V.C.:

Alienating Parent: ♀

“On January 17, 2006, the trial court entered its judgment, which adjudicated V.C. a CHINS as to Mother, but not as to Father. The judgment is sixty pages long and contains more than four hundred and fifty-eight findings of fact and conclusions of law. We now highlight a portion of those findings and conclusions: 371. Intent is a purely mental function and without a confession, it must be determined from a consideration of the conduct and the natural consequences of the conduct. The natural consequence of [Mother’s] conduct in lodging false reports of [sexual] abuse against [Father] was the alienation of [V.C.] from [her father].”
In re V.C., 867 N.E.2d 167, 171, 175 (Ind.App. 2007).

Meng v. Meng:

[UNPUBLISHED]

Alienating Parent: ♀

“The Court finds that Dr. Richard Lawlor did not make a specific recommendation about the custody of the minor children, and in fact in his written report and again by way of his testimony, stated that he could not find anything wrong with the recommendations that were made by Joyce Lowry. He saw each parent as about equally positioned in terms of their mixtures of positive and negative personality characteristics. He did opine that if the court found that [Mother’s] consistent attempts over the years to alienate the children from their father is the primary issue, then the children should live with [Father] and custody should change. However, Dr. Lawlor also referenced [Father’s] chronic harassment and denigration of [M]other as potentially allowing [Father] to become the alienating parent if custody is modified.”
Meng v. Meng, 866 N.E.2d 876 at *1 (Table) (Ind.App. 2007).

T.N. v. B.D.:

[UNPUBLISHED]

Alienating Parent: ♀

“To be sure, the record establishes that Father has a loving, bonded relationship with his daughter, as does Mother. Father has been able to build this bond over the years, and K.D. has also developed a strong relationship with Father’s wife and his step-son, who is K.D.’s age. Instead of fostering these important bonds, Mother has engaged in repeated and often extreme attempts . . . to alienate Father from his daughter. Mother’s abrupt withdrawal of K.D. from school, her move to Tennessee (in clear violation of the relocation statute), and her subsequent violations of the court’s visitation order . . . are just the latest examples of this.”
T.N. v. B.D., 895 N.E.2d 740 (Table) (Ind.App. 2008).

Victery v. Victery:

[UNPUBLISHED]

Alienating Parent: ♀

“The potential impact of changing VV’s custody from Mother to Father is minimal, whereas the actual impact upon VV remaining in Mother’s care is detrimental to VV’s best interests as a result of her ongoing attempts to alienate Father and Father’s family from VV’s life.”
Victery v. Victery, 893 N.E.2d 778 at *10 (Table) (Ind.App. 2008).

D.B. v. M.B.V.:

Alienating Parent: ♀

“The Hendricks Circuit Court conducted hearings on February 19, 2008, June 19, 2008, and January 14, 2009. Dr. Ehrmann testified that he began working with the family several years previously, and had conducted a custody evaluation and reunification therapy. In his opinion, reunification between Father and his children was undermined by Mother’s systematic alienation of the children from their father in order to redress Father’s conduct during the marriage. Dr. Ehrmann testified to his observations of the children’s aggression toward Father in that they would ‘bait, taunt, and insult’ Father. (Tr. 66.) He expressed concern that unsupervised parenting time would subject Father to the risk of false accusations of abuse and possible arrests.”
D.B. v. M.B.V., 913 N.E.2d 1271, 1273 (Ind.App. 2009).

In re Paternity of T.F.-W.:

[UNPUBLISHED]

Alienating Parent: ♀ — Custody to target parent: ♂

“On July 28, 2010, the trial court began an evidentiary hearing on Father’s petition to modify custody. At the hearing, Clinical Psychologist Victoria Dalton, Psy.D., testified on Father’s behalf. Dr. Dalton testified regarding parental alienation. . . . Dr. Dalton . . . testified, without challenge, that a risk of parental alienation is critical at the child’s current age, that is, before preteen years. If efforts to rectify the possibility of such alienation are not taken, then there may not be productive ways to treat it, if any, until adulthood.”
In re Paternity of T.F.-W., 950 N.E.2d 38 at **2, 4 (Table) (Ind.App. 2011).

<< Back