National Coalition Against Parental Alienation

Promoting Awareness and Solutionssm

Haase v. Haase:

Alienating Parent: ♀

“A licensed professional counselor testified that Benjamin was torn between his parents and had been alienated against his father by his mother.”
Haase v. Haase, 20 Va.App. 671, 460 S.E.2d 585, 587 (Va.App. 1995).

Begins v. Begins:

Alienating Parent: ♂ — Remanded after strongly disagreeing with judge who gave custody to alienator

“The [lower] court found that father did not ‘deserve to win custody’, yet reasoned that he had ‘effectively done so’ as a result of his own misconduct, and thus concluded that it had no other choice but to award custody to father. . . . We categorically reject such reasoning. ‘[A] parent who willfully 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) (emphasis added). Although obviously well intended, the court’s decision effectively condoned a parent’s willful alienation of a child from the other parent. Its ruling sends the unacceptable message that others might, with impunity, engage in similar misconduct. Left undisturbed, the court’s decision would nullify the principle that the best interest of the child are furthered through a healthy and loving relationship with both parents.”
Begins v. Begins, 168 Vt. 298, 302, 721 A.2d 469 (Vt. 1998).

Meyer v. Meyer:

Alienating Parent: ♂ — Custody to target parent: ♀

“[T]here was extensive evidence of father attempting to alienate Hannah and Hillary from mother that independently supports the court’s disposition in this case [ordering that custody be changed from joint custody to sole legal and physical custody of mother].”
Meyer v. Meyer, 173 Vt. 195, 200, 789 A.2d 921 (Vt. 2001).

Spaulding v. Butler:

Alienating Parent: ♂

“[T]he court’s conclusion in this regard is undermined by its findings that father intentionally alienated Nathan from mother, thereby eroding mother’s relationship with Nathan and enabling father to become Nathan’s primary caretaker.”
Spaulding v. Butler, 172 Vt. 467, 480, 782 A.2d 1167 (Vt. 2001).

Sundstrom v. Sundstrom:

Alienating Parent: ♀ — Custody to target parent: ♂

“Mother appeals from the family court’s order modifying parental rights and responsibilities, and awarding custody of the parties’ two minor children to father. The court found that mother’s ‘ongoing, intentional, mean-spirited violations’ of court orders concerning parent-child contact constituted a material and substantial change of circumstances, and the harm caused by mother’s obstruction of visitation outweighed the harm that could be caused by a change in custody. The court thus concluded that the children’s best interests required that they be removed from mother’s home and placed with father. On appeal, mother argues that the court abused its discretion in awarding custody to father, and committed various procedural mistakes that constitute reversible error. [Affirmed except with respect to a limited child support issue.] . . . The court . . . addressed whether the harm caused by mother’s obstruction of visitation outweighed the harm that could be caused by a change of custody. The overriding issue, the court explained, was the best interests of the children. The court concluded that not only had mother repeatedly and continuously interfered with father’s contact with the children, she had also intentionally worked to alienate the children from father by telling them that he had not been paying all of his child support. She further alienated them by placing them in the middle of that dispute by . . . having them say mean things to father over the phone. The court found that these attempts at parental alienation weighed against mother being the children’s sole custodian. The court concluded that the damage to the children from mother’s involvement of them in her disputes with father was extremely harmful to the children, and to the children’s relationship with father.”
Sundstrom v. Sundstrom, 177 Vt. 577, 577, 580-81, 865 A.2d 358 (Vt. 2004).

Sawwan v. Huang:

[UNPUBLISHED]

Alienating Parent: ♂

“The evidence supports the trial court’s finding that father’s conduct caused psychological and emotional injury to daughter resulting in her request to terminate his visitation. In addition, father alienated daughter through his repeated condemnation of mother.”
Sawwan v. Huang, 2005 WL 2205634 at *3 (Va.App.).

Coons v. Coons:

[UNPUBLISHED]

“The court also relied on a court-ordered forensic evaluation of the family by Dr. John Donnelly, who concluded that an award of legal custody to father could increase the children’s alienation from mother.”
Coons v. Coons, 2006 WL 5868292 at *3 (Vt.).

Weaver v. Lloyd:

[UNPUBLISHED]

Alienating Parent: ♀ — Custody to target parent: ♂

“On August 26, 2005, the trial court granted father’s petition and awarded him custody of the children. It noted that mother’s initial complaints ‘were unfounded’ and ‘[t]hey were continually unfounded.’ It found that mother’s ‘alienation was established’ and that the children ‘appear to be thriving,’ thus justifying a change in custody. The trial court also found that it was in the children’s best interests to change custody to father.”
Weaver v. Lloyd, 2006 WL 1888689 at *2 (Va.App.).

Eisenhardt v. Anderson:

[UNPUBLISHED]

Alienating Parent: ♀

“Father appeals the family court’s order declining to transfer to him physical parental rights and responsibilities with respect to the parties’ daughter. . . . The real issue in this case is not whether the evidence supports the court’s statement that mother’s conduct had alienated the child from father, but rather whether the court abused its discretion by maintaining physical parental rights and responsibilities with mother in light of mother’s alienating conduct. . . . Here, the family court called this a very close case, but declined to transfer physical custody of the child for. . . . Upon review of the record, we conclude that the court acted within its discretion in increasing father’s parent-child contact and transferring legal, but not physical, rights and responsibilities to father.”
Eisenhardt v. Anderson, 2007 WL 5313302 at **1, 2, 3 (Vt.)

Kasper v. Kasper:

Alienating Parent: ♀♂

“In evaluating the factors set forth in 15 V.S.A. § 665, the family court concluded that both parties had involved the children in their marital disputes, ‘including within the court’s observation. Mr. Kasper has done this to a greater extent than Ms. Kasper. In addition, he has fostered the children’s alienation from their mother.’”
Kasper v. Kasper, 181 Vt. 562, 562, 917 A.2d 463 (2007).

Miller v. Miller:

Alienating Parent: ♀

“The family court’s findings support its exercise of jurisdiction because, wherever the child was located, it was only in furtherance of mother’s kidnapping and alienation of the child from his father. Mother’s refusal to respond to process precluded findings by the court about the child’s ‘home state,’ his connections to another state or the availability of evidence. Id. § 1036(c)(1)- (3). These findings are not challenged.”
Miller v. Miller, 184 Vt. 464, 493, 965 A.2d 524 (Vt. 2008).

Chickanosky v. Chickanosky:

Alienating Parent: ♀ — Custody to target parent: ♂

“The court . . . noted Dr. Hasazi’s conclusion that if daughter were to reside with mother during the school year, father’s worries about parental alienation would be well-founded. Although mother highlights what she terms the ‘speculative’ nature of these findings, we conclude that they support the court’s determination of this factor, which was well within its discretion.”
Chickanosky v. Chickanosky, 35 A.3d 132, 142 (Vt. 2011).

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