National Coalition Against Parental Alienation

Promoting Awareness and Solutionssm

Bielaska v. Orley:

[UNPUBLISHED]

Alienating Parent: ♀ — Custody to target parent: ♂

“Dr. Campbell testified that the children were subjected to suggestibility. He testified that there is evidence of ‘parental alienation syndrome’ where the children are being alienated from their father to the extent that they don’t even recognize that he is their father, and that that foretells very serious consequences for these children unless it is corrected.”
Bielaska v. Orley, 1996 WL 33324080 at *23 (Mich.App.) (emphasis added).

George v. George:

[UNPUBLISHED]

Alienating Parent: ♀ — Custody to target parent: ♂

“The trial court determined that defendant had already alienated her son from his father. The trial court also adopted the report of Elaine Bryant as support for this conclusion.”
George v. George, 1998 WL 1989958 at *5 (Mich.App.).

Krieger v. Krieger:

[UNPUBLISHED]

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

“Dr. Richard Gardner testified for the defense that he prepared a report and concluded that defendant was not engaging in parental alienation, that defendant should be awarded custody of the four children, and that the problems between the children and plaintiff were a result of plaintiff’s own neglect and abuse, and plaintiff’s being schizophrenic, paranoid, delusional and psychotic.”
Krieger v. Krieger, 1999 WL 33453292 at *2 (Mich.App.) (emphasis added).

In re Spencley:

[UNPUBLISHED]

Alienating Parent: ♀ — Temporary custody to the State

“Although appellant argues that this case presents an issue of first impression because the family court relied on ‘parental alienation syndrome’ as a factual basis for assuming jurisdiction, we believe that petitioner properly responds that the family court’s factual findings are amply supported by the record and that the term ‘parental alienation syndrome’ is merely a way of describing appellant’s actions as they related to the circumstances of this case. At trial, one of the psychologists who had worked with the family, described appellant’s behavior as ‘parental alienation syndrome’ simply as a way of describing her behavior. In other words, there was evidence that appellant was, during the course of the divorce, attempting to alienate the children from their father. . . . Although appellant disputes the legitimacy of this theory, we agree with petitioner that the psychologist’s use of this theory at trial was merely a way to explain appellant’s behavior to deprive the children of their emotional well-being. In fact, there was a great deal of evidence that appellant was manipulating the children to alienate them from their father.”
In re Spencley, 2000 WL 33519710 at *4 (Mich.App.) (emphasis added).

Hopkins v. Whittemore:

[UNPUBLISHED]

Alienating Parent: ♀

“Following defendant’s motion for a change in custody, the trial court entered an order stating that a custody evaluation was appropriate, ‘because of possible parental alienation.’”
Hopkins v. Whittemore, 2004 WL 539085 at *1 (Mich.App.).

Ostermann v. Ostermann:

[UNPUBLISHED]

Alienating Parent: ♂♀

“Defendant engaged in parental alienation as well, albeit to a lesser degree. The expert psychologist who testified below, and who pointed out plaintiff’s parental alienation, found no evidence of significant mental problems in either party.”
Ostermann v. Ostermann, 2005 WL 2323410 at *2 (Mich.App.).

Lopez-Negrete v. Lopez-Negrete:

[UNPUBLISHED]

Alienating Parent: ♀

“Dr. Hobbs also testified regarding her psychological evaluation of defendant. According to Dr. Hobbs, defendant had problems with anger and ‘her distaste for her husband negates his being in a sense.’ She further stated that defendant was ‘so consumed with her negativity and her anger at her husband that the air he breathes is toxic.’ Dr. Hobbs also stated that defendant’s anger toward plaintiff could lead to a situation called parental alienation, in which a child will not acknowledge a single positive thing about the other parent.”
Lopez-Negrete v. Lopez-Negrete, 2009 WL 1506668 at *15 (Mich.App.).

Stadel v. Stadel:

[UNPUBLISHED]

Alienating Parent: ♀♂

“Regarding factor (l), the trial court concluded: ‘The theme at trial suggested a low- to mid-level of mutual parental alienation.’”
Stadel v. Stadel, 2009 WL 2974894 at *5 (Mich.App.)

Meadows v. Meadows/Henderson:

[UNPUBLISHED]

Alienating Parent: ♀ — Custody to target parent: ♂

“[P]sychologist John D. Ulrich, Ph.D., testified that he concluded that defendant had engaged in a pattern of parental alienation. . . . Ulrich described parental alienation as ‘[t]he process of one parent trying to undermine and destroy to varying degrees the relationship that the child has with the other parent.’ This finding is also not against the great weight of the evidence.”
Meadows v. Meadows/Henderson, 2010 WL 3814352 at *3 (Mich.App.).

Lasley v. Miller:

[UNPUBLISHED]

Alienating Parent: ♀

Notes: Higher court disagreed with lower court’s findings of parental alienation.

“Under factor L, the catch-all factor, the court found that the child had been alienated from society and from her father at times, and again noted that plaintiff coached her before meeting with [court-appointed masters psychologicst counselor and evaluator Lynn] Clynick. However, there was no evidence to support the court’s finding of alienation, as Clynick testified that she did not see evidence of parental alienation.”
Lasley v. Miller, 2011 WL 5248214 at *8 (Mich.App.).

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