National Coalition Against Parental Alienation

Promoting Awareness and Solutionssm

Theisen v. Theisen:

Alienating Parent: ♀ — Custody to target parent: ♂

“The trial court also found that appellant had ‘consistently engaged in a pattern of unwarranted and willful interference with [r]espondent’s right of visitation . . . and has made repeated attempts to alienate the children from their father.’”
Theisen v. Theisen, 405 N.W.2d 470, 472 (Minn.App. 1987).

Crews v. McKenna:

[UNPUBLISHED]

Alienating Parent: ♀ — Custody joint with target parent: ♂

“Devries noted some of B.C.’s behavior evidenced ‘parental alienation syndrome.’”
Crews v. McKenna, 1998 WL 373283 at *2 (Minn.App. 1998).

Jokippi v. Miller:

[UNPUBLISHED]

Alienating Parent: ♀

“The district court heard evidence on various dates between February 19, 1997 and April 11, 1997 and then, on June 13, 1997, issued its Order Amending Judgment and Decree. In that order, the district court cited numerous examples of respondent’s obstruction of appellant’s visitation rights, including respondent’s antagonism toward his visitation suggestions; inflexibility about compromising visitation issues; proclivity for expressing her anger toward appellant and making derogatory statements about appellant in the presence of the child, and for actively involving the child in the parties’ conflicts; interference with telephone visitation; pattern of parental alienation in which she actively undermined the child’s relationship with appellant; and her lack of cooperation with the guardian ad litem and the child’s psychologist.”
Jokippi v. Miller, 1998 WL 74289 at *3 (Minn.App.).

Smith v. Smith:

[UNPUBLISHED]

Alienating Parent: ♀

“In March 2001, the court held that it would be in A.S.’s best interests to be placed with respondent. The court pointed out that appellant (1) interfered with respondent’s visitation with their daughter; (2) alienated their daughter’s affections for respondent; and (3) mismanaged her anger. In April 2001, the court denied appellant’s motion for a new trial. This appeal followed.”
Smith v. Smith, 2001 WL 1608365 at *1 (Minn.App.).

In re Weber:

Alienating Parent: ♂ — Custody to remain with target parent: ♀

“Taken together, the record supported the conclusions that . . . ‘the signs of alienation could not be more clear-a campaign of hatred, a failure of guilt on the minor child for treating the parent with malice, the parroting of adult language, and a declaration of independence.’”
In re Weber, 653 N.W.2d 804, 810 (Minn.App. 2002).

Breitenfeldt v. Nickles-Breitenfeldt:

[UNPUBLISHED]

Alienating Parent: ♀

“[Court-appointed psychologist Mindy] Mitnick stated in her evaluation: [Mother’s] pattern of making vague reports of abuse and neglect and then denying responsibility for the subsequent Child Protection investigations is of much concern to the evaluator. Such a pattern often is associated with parental alienation dynamics as the child gets older and can voice his ‘wishes.’ The risk is clearly present for [mother] to share her negative views of [father] with or within hearing of [son] and then to use [son’s] resulting anxiety or acting out as evidence of the need for restricted contact.”
Breitenfeldt v. Nickles-Breitenfeldt, 2003 WL 1908070 at **1, 3 (Minn.App.).

Behnke v. Green-Behnke:

[UNPUBLISHED]

Alienating Parent: ♀

“The court described appellant as ‘manipulative, paranoid, emotionally charged, and reclusive,’ as harboring ‘delusional beliefs,’ and as ‘well on her way to accomplishing total parental alienation between [respondent] and the children.’ The court observed that appellant admitted that she was no longer treating her mental illness with medication or therapy.”
Behnke v. Green-Behnke, 2004 WL 376984 at *2 (Minn.App.).

Capra v. Capra:

[UNPUBLISHED]

Alienating Parent: ♂ — Custody to target parent: ♀

“Father argues that the evidence does not support the best-interests findings, but a thorough review of the record demonstrates otherwise. . . . The finding that father’s current caretaking responsibilities are the result of parental alienation is supported by mother’s testimony that, since the dissolution, father has employed several techniques to alienate her from the children, such as demeaning her and insulting her parenting skills in the children’s presence and preventing her from talking to the children on the telephone.”
Capra v. Capra, 2007 WL 3146810 at *3 (Minn.App.).

Adler v. Espinosa:

[UNPUBLISHED]

Alienating Parent: ♀

“The district court concluded for purposes of the statutory modification requirement, that MA-E’s ‘emotional development is impaired in the environment of [Adler’s] sole legal and physical custody because [Adler] will not permit the child to have a normal relationship with [Espinosa], and [Adler] will cause [MA-E] distress by systematically undermining [Espinosa’s] involvement with the child.’ The record supports the district court’s findings that provide the basis for the conclusion. The evidence established that Adler has prohibited Espinosa from having parenting time for months at a time; disparaged Espinosa to MA-E on a regular basis; has instructed MA-E about the custody battle; has exposed MA-E to undue medical and legal scrutiny in an attempt to obtain evidence that Espinosa mistreated MA-E; has ‘played games’ with MA-E in which they create stories about Espinosa’s alleged mistreatment; and has imparted religiously intolerant information to MA-E about Espinosa and his wife. The evidence shows that when MA-E was in Adler’s custody she was angry, withdrawn, and physically aggressive with other children and that her behavior improved when custody was transferred to Espinosa under the temporary order. . . . From this evidence, the district court could reasonably determine that MA-E’s emotional development was impaired under Adler’s custody. See Theisen v. Theisen, 405 N.W.2d 470, 474 (Minn.App. 1987) (holding that endangerment element was satisfied mainly because mother’s false accusations alienated children from their father and impaired their future relationship with him).”
Adler v. Espinosa, 2008 WL 4471303 at **2-3 (Minn.App.).

Adolphson v. Yourzak:

[UNPUBLISHED]

Alienating Parent: ♀

“Based upon the report of a HCFCS custody evaluator and testimony introduced at the hearing, the district court concluded that mother would engage in parental alienation if granted sole authority over L.A.Y. As an example of this, the district court noted that, after father marked one of L.A.Y.’s karate shin guards with the boy’s full initials, ‘L.A.Y.,’ mother blacked out the ‘A,’ which stands for the father’s last name.”
Adolphson v. Yourzak, 2008 WL 4628722 at *4 (Minn.App.).

Arnholt v. Arnholt:

[UNPUBLISHED]

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

“The district court found that, although [court-appointed custody evaluator Mindy] Mitnick opined that the children’s poor relationship with appellant was due to respondent’s attempts to alienate the children from appellant, the district court had listened to tapes made by appellant of parenting exchanges and phone conversations and was not convinced that alienation was occur-
ring. . . . The district court also found that three other experts-Shea, Mullenbach, and Lynch-all discredited Mitnick’s conclusions to some extent.”
Arnholt v. Arnholt, 2010 WL 3744365 at **3-4 (Minn.App.).

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