National Coalition Against Parental Alienation

Promoting Awareness and Solutionssm

McAdams v. McAdams:

Alienating Parent: ♂ — Higher court disagreed with District Court. Case remanded to new judge

“The sole rationale employed by the district court for splitting custody was the alienation between Kenneth and Carmen McAdams. The district court found ‘the father has manipulated the older son, Kenneth, to where the alienation between Kenneth and his mother is very strong. The Court finds that this alienation exists because of the father’s conduct.’ The district court then concluded Kenneth should be placed with his father because it would require ‘major and significant professional help’ to reconcile Kenneth’s relationship with his mother. The court also concluded Bryan was no yet significantly alienated from his mother, and would become completely alienated if placed with his father. Thus, Bryan should be placed with his mother. This Court does not look favorably upon split custody. . . . The district court’s decision effectively terminates Kenneth’s relationship with his mother. By awarding custody of Kenneth to his father, the parent who has poisoned Kenneth’s mind and will likely continue to do so, Kenneth alienates a child from the other parent may not be awarded custody based on that alienation.”
McAdams v. McAdams, 530 N.W.2d 647, 650 (N.D. 1995).

Hendrickson v. Hendrickson:

Alienating Parent: ♀

“The district court’s order relied heavily upon the child custody evaluation report of Mueller which concluded Diane’s alienation was through both overt and covert patterns of behavior. The order further read: If there were any practical way under these circumstances, I would award custody to Mark. Before that happens, Diane has an opportunity to undo what she has done. To that end, from Stutsman County Social Services I will receive a report in ninety days. If that report reveals that Diane has engaged in any alienating behavior, Diane will forthwith commence serving thirty days in the Southwest Multi-County Corrections Center for contempt. If that report reveals that either party has not fully cooperated in the therapeutic process or has hindered it in any way, that party will serve thirty days. If the report reveals no improvement in the relationship between children and father, I will take it as prima facie evidence that Diane continues subtle alienating behavior and instruct the sheriff accordingly.”
Hendrickson v. Hendrickson, 590 N.W.2d 220, 222 (N.D. 1999).

Hendrickson v. Hendrickson:

Alienating Parent: ♀ — Custody parent did not change

“In its order, the court found Diane had frustrated visitation between Mark and the children and had attempted to alienate the . . . children from their father.”
Hendrickson v. Hendrickson, 603 N.W.2d 896, 899-900 (2000 N.D. 1).

Anderson v. Resler:

Alienating Parent: ♀

“The record evidence shows Resler has repeatedly denied visitation privileges to Anderson during these formative years of the child’s life. Resler has told others herspecific intent isto terminate Anderson’s rights as a parent to the girl. There is also evidence Resler has attempted to alienate the child’s affection for Anderson. During more than one phone conversation between the girl and Anderson, she was coached to say such things as, ‘I don’t like . . . you anymore,’ ‘you are a bad daddy,’ and ‘pay your support.’”
Anderson v. Resler, 618 N.W.2d 480, 485-86, 2000 ND 183.

In re C.H.:

Alienating Parent: ♀ — Custody to target parent: ♂, but alienator later prevails with help from social services

“This case signals the need for earlier and effective intervention in cases such as this one, with truly egregious examples of one recalcitrant parent frustrating visitation and alienating children against the other parent.”
In re C.H., 622 N.W.2d 720, 725 (2001 N.D. 37).

In re T.T.:

Alienating Parent: ♀

“At the deprivation hearing, the mother objected to Dr. Timm’s testimony, claiming he did not have the expertise or requisite experience to testify about parental alienation. After further foundation was provided, the court allowed Dr. Timm to testify about parental alienation, ruling his experience qualified him to testify on the subject.”
In re T.T., 681 N.W.2d 779, 784 (2004 N.D. 138).

Wolt v. Wolt:

Alienating Parent: ♂ — Custody to target parent: ♀

“The court found credible evidence of alienation by Steve Wolt, in that the two older children were totally alienated from their mother and the youngest child would also succumb to alienation if the parenting situation continued.”
Wolt v. Wolt, 778 N.W.2d 786, 793, 2010 ND 26.

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