National Coalition Against Parental Alienation

Promoting Awareness and Solutionssm

Gentry v. Simmons:

Alienating Parent: ♀ — Custody to target parent: ♂

Notes: the Eatherton case is not included here because the Court in that case did not ultimately find that alienation took place, and no experts testified.

“The evidence, including the mother and stepfather’s own testimony, indicated that they held the father in low regard, degraded him in Jamie’s presence, depicted him as an evil person with whom Jamie should have no contact and engaged in persistent efforts to destroy Jamie’s natural affection for her father. The mother expressed it as her preference that Jamie have nothing to do with her father, a directive which Jamie continually resisted. This state of facts showing an attempt by one parent to alienate a child from the other parent is a changed condition and can form the basis for a modification of custody, Eatherton v. Eatherton, 725 S.W.2d 125, 128 (Mo.App. 1987). When a parent who has custody makes disrespectful and abusive statements against the other parent and attempts to wean the children away, the decree can properly be modified and the custody changed. Garrett v. Garrett, 464 S.W.2d 740, 743 (Mo.App. 1971).”
Gentry v. Simmons, 754 S.W.2d 579, 582 (Mo.App. W.D. 1988).

Cornell v. Cornell:

Alienating Parent: ♀

“There was substantial evidence to support a finding that wife allowed a pattern of interference with the visitation and temporary custody granted to husband. There was evidence from which the trial court could conclude wife was attempting to alienate the daughter from husband.”
Cornell v. Cornell, 809 S.W.2d 869, 874 (Mo.App. S.D. 1991).

Kessinger v. Kessinger:

Alienating Parent: ♀

“Moreover, the court found the child’s testimony had been rehearsed with mother and mimicked mother’s testimony and that, although the mother . . . had directed the child to visit father, mother had alienated the child from father. The findings of the trial court are supported by substantial evidence.”
Kessinger v. Kessinger, 829 S.W.2d 658, 663 (Mo.App. E.D. 1992).

Schaffer v. Haynes:

Alienating Parent: ♀

“In its order, the trial court found that wife had alienated the children’s affections from their father and ‘substantially, willfully, denied [him his] temporary custody and visitation.’”
Schaffer v. Haynes, 847 S.W.2d 814, 820 (Mo.App. E.D. 1992).

Gulmen v. Gulmen:

Alienating Parent: ♂ — Children too old to change custody

“[T]he Court . . . finds that Husband purposely engaged in conduct, the collective effect of which caused both minor children to become alienated from their mother.”
Gulmen v. Gulmen, 851 S.W.2d 37, 38 (Mo.App. E.D. 1993).

Jones v. Jones:

Alienating Parent: ♀ — Custody to target parent: ♂

“[T]he court found mother’s interference with father’s visitation rights made changing custody from mother to father to be in the best interests of the child. Section 452.400 RSMo 1994. It is the . . . policy of this state to encourage the continued interest, love and affection of both divorced parents for their children and to afford children ample opportunity for close contact with them. Cornell, 809 S.W.2d 869, 873 (Mo.App. 1991). Facts showing an attempt by one parent to alienate a child from the other parent can form the basis for a modification of custody. Id. Thus, there was evidence to support a modification of custody.”
Jones v. Jones, 902 S.W.2d 363, 365-66 (Mo.App. E.D. 1995).

Wilson v. Sullivan:

Alienating Parent: ♀♂ — Transfer of custody from father to mother upheld

“Although the court found father culpable of behavior alienating to the mother-child relationship, the court found mother’s pattern of behavior more egregious.”
Wilson v. Sullivan, 922 S.W.2d 835, 837 (Mo.App. E.D. 1996).

Nichols v. Beran:

Alienating Parent: ♀ — Custody to target parent: ♂

“In its Order, the trial court thus specifically found that Mother had made ‘every effort to destroy the relationship of the children with their father and has denied, refused and interfered with visitation to the father without good cause. The mother repeatedly belittles and denigrates the father to the children.’ The policy of this State is to encourage continued loving and caring relationships between divorced parents and their children to afford ample opportunity for close contact between both parents and their children. Our courts have previously held that facts showing an attempt by one parent to alienate a child from the other parent can form the basis for modification of custody. See Wilson v. Sullivan, 922 S.W.2d 835, 837 (Mo.App. 1996).”
Nichols v. Beran, 980 S.W.2d 342, 347 (Mo.App. 1998).

Stevens v. Stevens:

Alienating Parent: ♀ — Custody to target parent: ♂

“The guardian ad litem recommended joint legal custody and primary physical custody with the Respondent father. The guardian ad litem based her recommendations on her findings that Appellant greatly interfered with the visitation and relationship between Respondent and the child. The guardian ad litem was also concerned with the child’s mental health, welfare and development. The trial judge then stated that the court’s observations from hearing the evidence were essentially the same as the recommendation made by the guardian ad litem. The trial judge went on to say, ‘I think the mother had made substantial efforts to alienate the father from the child by denying and preventing visitation. I think the allegations of the [Appellant’s] affidavit are essentially unsubstantiated. I think there is recklessness and misstatement in that affidavit.’ The trial court’s judgment entry order of dissolution ordered the immediate transfer of physical custody to Respondent.”
Stevens v. Stevens, 977 S.W.2d 305, 308 (Mo.App. W.D. 1998).

Pirisky v. Meyer:


Alienating Parent: ♀

“The trial court found Mother had refused to allow Father to exercise his rights of visitation and temporary custody and that Mother began alienating Child from Father as soon as Child expressed an interest in residing with Father.”
Pirisky v. Meyer, 2004 WL 2590493 at *2 (Mo.App. E.D.).

Cantwell v. Cantwell:

Alienating Parent: ♂ — Custody to target parent: ♀

“The court found that Father continuously attempted to alienate Michael from Mother, that Father had a pattern of making false complaints to the Division of Social Services related to Mother, that Father had failed to adhere to the parenting time schedule, and that Mother and Father were incapable of communicating regarding their children. [Father failed to file a transcript of hearings with his appeal of the lower court judgment granting mother’s motion for sole legal custody: appeal dismissed.]”
Cantwell v. Cantwell, 315 S.W.3d 384, 386 (Mo.App. W.D. 2010).

Noland Vance v. Vance:

Alienating Parent: ♀ — Custody to target parent: ♂

“Dr. Aram concluded that Mother’s constant negativity towards Father, by berating him in front of the children and inciting their fear of him, had caused the children to suffer severe trauma. Relying upon literature in the field, Dr. Aram explained that there were ten indicators of parental alienation. All ten indicators were present in this case. Dr. Aram described this situation
as the worst case of parental alienation he had ever seen.”
Noland-Vance v. Vance, 321 S.W.3d 398, 405 (Mo.App. 2010).

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