Recurrent Misinformation Regarding Parental Alienation Theory

Figures & data

Table 1. Between 1994 and 2020, the same misinformation regarding parental alienation theory was published 40 times in journal articles, book chapters, professional presentations, a legal brief, and policy statements of professional organizations.

Citation and Published Misinformation	Comment
(1) Cheri Wood (1994). “In short, the psychological stressors resulting from divorce demonstrate that children’s ill feelings toward either parent are often a natural part of the dissolution process. The list of explanations—which is illustrative rather than exhaustive—that provides reasons for children having such feelings furnishes some credible alternatives to the PAS theory that when the children have ill feelings toward their fathers, their mother must be the cause” (emphasis added) (p. 1390).	- There has never been a principle of PAS theory “that when the children have ill feelings toward their fathers, their mother must be the cause.” Wood provided no source for that statement.
(2) Danielle Isman (1996). “According to Gardner, PAS manifests in children who unjustly deprecate or criticize a parent. In other words, Gardner believes that whenever a child expresses dislike of or apprehension about contact with the father, and the mother is the primary care-taker, the reason for the child’s reservations about the father are caused by the mother’s abuse” (emphasis added) (p. 13).	- Isman did not cite any source in Gardner’s writings or anywhere else for this false statement, although she did cite Wood (1994) elsewhere in her article.
(3) S. Margaret Lee and Nancy W. Olesen (2001). “There are a number of problems associated with the evaluations that involve questions of alienation. Many evaluations lack depth and completeness and stop at the simplistic finding of “parental alienation syndrome” (PAS) as described by Gardner (1987). That is, one parent is identified as engaging in alienating behavior and/or the child is resisting visits. This conclusion infers causality and leads to a set intervention strategy. In the most disturbing situations of PAS, it is reasoned that when one determines that a child is alienated, it follows that a parent is engaged in brainwashing” (p. 283).	- Although Lee and Olesen cited Gardner (1987), there is no statement in that book to the effect that it is acceptable to reason “that when one determines that a child is alienated, it follows that a parent is engaged in brainwashing.”
(4) Carol S. Bruch (2001). “PAS shifts attention away from the perhaps dangerous behavior of the parent seeking custody to that of the custodial parent. This person, who may be attempting to protect the child, is instead presumed to be lying and poisoning the child” (emphasis added) (p. 532).	- Bruch provided no citation or other evidence for the suggestion that PA proponents presume that contact refusal is caused by alienating behaviors of the favored parent.
(5) Elspeth McInnes (2003). “PAS begins from the premise that children who allege serious abuse by a parent are lying and that they are made to lie by an apparently protective parent. … Children’s complaints of harm by a parent are, within the logic of PAS, proof that the child is subject to PAS of by the other parent” (p. 4).	- There is no such premise within PAS/PA theory. McInnes offered no citation for this incorrect statement.
(6) Paula J. Caplan (2004). “A parent who refuses to force the children to visit their father (even when an abuse allegation is still being investigated) or does not “cooperate” with a court-ordered assessment is assumed to be involved in PAS rather than possibly perceiving accurately or even reasonably believing that the father or assessor may be biased against her child” (emphasis added) (p. 63).	- Caplan said that in cases of contact refusal (in which children are not visiting their father), the evaluator assumes that the mother is alienating the children without considering other possibilities. Caplan provided no source for that false statement.
(7) G. Kim Blank and Tara Ney (2006). “The child’s story … is always, according to Gardner, the product of brainwashing on the part of the parents” (emphasis in original) (p. 141). “Thus, in this area of high-conflict divorce involving non-visitation of a child, we see entrenched and polarized perspectives of power based on a specialized, privileged knowledge. On one hand, there ‘are those who deny the possibility that any child could develop an irrational alienation from a parent,’ and on the other, those, like Gardner, who hold that a parent is always to blame” (p. 146).	- Blank and Ney misinterpreted Gardner. Gardner (1982, p. 175) simply said that it is very common for parents to try to influence their children in the context of custody litigation. He did not say that all children are duly influenced; he did not say that contact refusal is always caused by the preferred parent.
(8) Jennifer Hoult (2006). “By diagnosing PAS solely on the basis of the child’s symptoms, the DDC tautologically presumes pathology, parental contribution, and lack of justification, the very factors that Gardner claimed distinguish PAS from other forms of [contact refusal]” (emphasis added) (p. 9).	- When Hoult cited “DDC,” she was referring “differential diagnosis criteria” Gardner (2004a). Nothing in that article suggests that Gardner thought PAS could be diagnosed “solely on the basis of the child’s symptoms” or that an evaluator should “presume pathology, parental contribution, and lack of justification.”
(9) Clare Dalton, Leslie M. Drozd, and Frances Q. F. Wong (2006). “The discredited ‘diagnosis’ of PAS (or an allegation of ‘parental alienation’) … inappropriately asks the court to assume that the child’s behaviors and attitudes toward the parent who claims to be ‘alienated’ have no grounding in reality” (emphasis added) (p. 24).	- Both documents published by the National Council of Juvenile and Family Court Judges made the same false statement regarding PA theory. Of course, no PA proponent asks the court to assume that the child’s contact refusal has no basis in reality. The diagnosis of PA requires a showing of alienating behaviors by the preferred parent, symptoms of PA in the child, and other factors. Dalton et al. cited Bruch (2001) to support their false statement regarding PA theory.
(10) Jerry J. Bowles, Kaye K. Christian, Margaret B. Drew, and Katheryn L. Yetter (2008). “The discredited ‘diagnosis’ of PAS (or an allegation of ‘parental alienation’) … inappropriately asks the court to assume that the child’s behaviors and attitudes toward the parent who claims to be “alienated” have no grounding in reality” (emphasis added) (p. 13).
(11) Andraé L. Brown (2008). “Unfortunately, the intentionally vague and undefined diagnostic criteria for PAS shift the focus from the abusing parent to the child. A frame is set in which all negative statements made by children about the noncustodial parent become evidence of alienation by the custodial parent” (p. 388).	- Brown cited no source for the false notion that PAS theory holds that “all negative statements made by children” about one parent are evidence of alienating behaviors by the other parent.
(12) Leslie M. Drozd (2009). “Parental alienation syndrome refers to a purported pattern of signs and symptoms occurring in the child that indicate the presence of alienating behavior in a parent that has resulted in the child’s alienation from the other parent” (p. 404). “Gardner claimed that the presence of several elements of this supposed syndrome indicated that the child had been induced to hate the alienated parent by the activities of the supposed alienating parent …” (p. 405).	- Neither Gardner nor subsequent PA proponents ever said that a child’s contact refusal is always caused by the alienating behaviors of the preferred parent. Drozd provided no reference in Gardner’s writings to support that claim.
(13) Joan S. Meier (2009). “It is this kind of circularity and conclusory reasoning that gives weight to the common accusation that PAS theory simply presumes that a child’s hostility toward a father is pathological and that mothers who make such allegations are doing so only to undermine the child’s relationship with the father” (emphasis in original) (p. 236).	- Meier provided no source for the presumption “that a child’s hostility toward a father is pathological,” caused by the alienating behaviors of the mother. Meier was correct that it was a “common accusation” that PAS theory made that presumption, but that notion cannot be found in the writings of Gardner or any other PA proponent. That presumption is only found in the writings of PA critics.
(14) Amy Neustein and Michael Lesher (2009). “Yet the assumption of a reliable correlation between a child’s fear and dislike of his father and a ‘campaign of denigration’ by the child’s mother was the heart and soul of Gardner’s PAS theory” (emphasis added) (p. 323).	- PAS theory never stated that a “campaign of denigration” by the mother could be assumed simply because a child expressed dislike of his father. Neustein and Lesher provided no reference for that claim.
(15) Miguel Clemente and Dolores Padilla-Racero (2015). “The term ‘campaign of denigration’ (Gardner, 1998, 1999a), assumes that the child is lying. And this is one of the main problems with this purported syndrome—its point of departure is the idea that children do not tell the truth because they are manipulated. Thus, if a child states that she does not want to see her father, this is explained as fruit of the mother’s manipulation, and the mother would be accused of being a manipulative mother. However, the hypothesis that the child is being physically or even sexually abused by her father is not contemplated and therefore not investigated” (emphasis added) (p. 102).	- Nothing in that paragraph can be found in the two citations to Gardner (1998, 1999a). Gardner’s concept of the “campaign of denigration” does not assume that the child is lying. It is not automatically concluded that a child’s contact refusal is caused by the “fruit of mother’s manipulation.” It is incorrect to say that PA proponents do not consider and investigate alternative hypotheses for a child’s contact refusal.
(16) Scott C. Huff (2015). “Gardner (1999b, 2004a), for example, uses child behaviors of contact refusal to diagnose the presence of severe alienating behavior by the parent” (p. 72).	- Huff was mistaken in citing Gardner (1999b, 2004a). Neither of those articles had anything to do with “[using] child behaviors of contact refusal to diagnose the presence of severe alienating behavior by the parent.” Huff may have been relying on Meier (2009), since that article was included in his references.
(17) William O’Donohue, Lorraine T. Benuto, and Natalie Bennett (2016). “Absent any scientific data at all, Gardener [sic] advanced the claim that when there is an alienating parent, a child will, fairly inevitably, develop a series of problematic behaviors and/or reactions. He also claimed that the reverse inference was valid; specifically, that clinicians could conclude that there is an alienating parent when they observed children exhibiting certain behaviors” (emphasis added) (p. 114).	- Both sentences are incorrect. PA advocates say that contact refusal is sometimes caused by the preferred parent’s alienating behaviors, but it may also have other causes. O’Donohue et al. provided no citation to Gardner or anyone else for these erroneous statements.
(18) Madelyn S. Milchman (2017). Milchman analyzed 24 published child custody cases from New York that involved allegations of parental alienation and/or child sexual abuse. In eight of the 20 father custody cases, “there was also affirmative evidence of PA.” In the other 12 father custody cases, “there was no affirmative evidence of PA” (p. 237). Milchman explained: “In the other 12 father custody cases with unfounded CSA allegations, there was no affirmative evidence of PA. The only PA evidence was the unfounded CSA allegations, which were interpreted as deliberate and malicious. … The equation of an unfounded CSA allegation with PA in the absence of direct evidence for PA is a dangerous equation …” (p. 237).	- PA was not a factor in any of the “other 12 father custody cases”: the topic of PA was not introduced by the fathers, their attorneys, the expert witnesses, or the court. Milchman imposed her own misconceptions regarding PA theory on the New York family law cases. She thought that making a false CSA allegation was equivalent to claiming PA, but they are not the same: many false CSA allegations have nothing to do with PA (as occurred in the 12 family law cases discussed by Milchman); many PA cases have nothing to do with false CSA allegations; and occasionally PA and false CSA allegations occur together.
(19) Suzanne Zaccour (2018). “Both leading models of PA(S) rely on the child: Gardner diagnoses PAS based on eight symptoms found in the child and assumes the alienating parent’s responsibility …” (emphasis added) (p. 1097).	- Neither Gardner nor PA proponents have made that assumption. Zaccour did not cite any resource for that incorrect statement.
(20) Linda C. Neilson (2018). Neilson discussed how claims of parental alienation affect evidence in family law cases in Canadian courts. She said: “Let us turn now to other assertions of parental alienation advocates testifying in Canadian cases to see how the assertions, if accepted by courts, would affect judicial fact finding and analysis of evidence. Parental alienation advocates advise courts to assume the presence of parental alienation when children resist contact with non-primary-care parents” (emphasis added) (p. 29).	- PA advocates do not assume the diagnosis of PA simply because children resist contact with a parent. In support of that misstatement, Neilson provided quotations from five trial and appellate cases from Canada. However, none of the cited cases involved a PA advocate’s advising the court or testifying to the effect that the court should assume the presence of PA whenever children manifest contact refusal.
(21) G. Andrew H. Benjamin, Connie J. Beck, Morgan Shaw, and Robert Geffner (2019). “[PAS] assumes that a child’s strong alignment with one parent while rejecting a relationship with the other parent is without legitimate justification …” (emphasis added) (p. 34).	- PA theory does not assume that a child’s contact refusal is without legitimate justification. Every PA proponent knows that PA is one possible explanation for a child’s contact refusal, but not the only possibility.
(22) Jean Mercer (2019a). “PA proponents have been guilty of circular reasoning since Gardner’s day (cf. Huff, 2015) in that they have omitted the collection of data about one parent’s persuasive efforts but have nevertheless assumed that [visitation resistance or refusal] (without “justified” causes like physical abuse) is in itself evidence that the preferred parent has carried out a campaign of denigration against the nonpreferred parent” (emphasis added) (p. 95).	- Mercer was relying on Huff (2015), who made a similar argument without any basis in the literature. Mercer provided no evidence for the claim that PA proponents assume that contact refusal “is in itself evidence that the preferred parent has carried out a campaign of denigration ….”
(23) Jean Mercer (2019b). “Gardner proposed that child or adolescent [visitation reluctance or refusal] should be identified as PA, and thus the result of the preferred parent’s actions, when certain criteria were met” (p. 352–353). “It is notable that the first criterion item, a campaign of denigration [by the preferred parent] is usually assumed rather than demonstrated” (emphasis added) (p. 353). “It is an error of logic to assume that when a child avoids a non-preferred parent, the preferred parent must have persuaded the child to do so. This fallacious assumption is a common error of critical reasoning called affirming the consequent, in which it is wrongly thought that if B follows A, B must always have been preceded by A, even though B might also (or instead) have been preceded by C, D, etc.” (emphases added) (p. 358).	- The two articles by Mercer (2019a, 2019b) stated the same error, i.e., claiming that PA proponents assume that all contact refusal is caused by the preferred parent’s alienating behaviors without considering other possible explanations. Mercer provided no source for that misinformation.
(24) Kimberley J. Joyce (2019). “From Gardner’s (1987) notion of PAS theory comes the critical relationship of cause and effect. PAS encapsulates a theory that the occurrence of certain ‘typical’ manifestations in a child has the common cause of a favored parent’s conscious or unconscious ‘brainwashing’” (p. 65). “It is a disorder that excludes other factors that might impact the parent–child relationship, and attributes responsibility exclusively to the favored parent. This is the underlying structure of the theory: a backwards-looking theory of cause and effect (i.e., when you see the effect, you can look backwards and infer the cause) that has not changed over the more than thirty years since Gardner’s (1987) book was first published” (emphases in original) (p. 66).	- There is no text in Gardner (1987) consistent with Joyce’s opinion that PAS theory requires that B (“manifestations in a child”) must have been preceded by A (parental “brainwashing”). PA proponents say that manifestations of PA in the child, such as contact refusal, might have been caused by parental brainwashing, but may have been caused by other factors.
(25) Joan S. Meier and Sasha Drobnick (2019). “Parental alienation … generally refers to the presumption that a child’s fear or rejection of one parent … stems from the malevolent influence of the preferred … parent. The alienation hypothesis inherently relies on two flawed assumptions: (i) that children do not ordinarily fear or resist a non-custodial parent without manipulation by the other parent; and (ii) that a child’s hostility toward or fear of the other parent can, in fact, be caused solely by the favored parent’s negative influence …, regardless of the child’s own experience” (emphases added) (pp. 2–3).	- Those misstatements appeared in an amicus brief filed in a child custody dispute at the New York Court of Appeals. Meier and Drobnick provided no source or evidence for those statements.
(26) Linda C. Neilson and Joan Meier (2019). “Empirically verified problems associated with the application of parental alienation theory … include: … Deflection of attention from scrutiny of parenting practices and parent–child relationships in favor of assuming primary-care parent blame when children have poor relationships with the other parent” (emphasis added).	- These authors asserted that PA proponents simply assume that the acts of the preferred parent are the reason for a child’s problematic relationship with the rejected parent. They provided no reference or any other basis for that statement.
(27) Joan S. Meier, Sean Dickson, Chris O’Sullivan, Leora Rosen, and Jeffrey Hayes (2019). “Parental alienation … is the theory that when a mother and/or child seek to restrict a father’s access to the child, their claims of dangerousness or harm are not true, but due to the mother’s anger or hostility, or pathology” (p. 4).	- Meier et al. assert that a child’s contact refusal automatically means that the mother caused it through false claims of dangerousness, without any further investigation. Meier et al. provided no source or citation within PA literature to that effect. This research in Meier et al. (2019) was also reported in Meier (2020).
(28) Joyanna Silberg and Stephanie Dallam (2019). Silberg and Dallam explained their study of overturned decisions, i.e., cases in which a court reversed an earlier court’s decision regarding a child’s custody. They said: “Our findings offer support to those who have noted that more recent theories of parental alienation do not present a significant improvement over Gardner’s original conceptualization of PAS (Houchin et al., 2012; Meier, 2013). For example, the various parental alienation theories utilized by professionals evaluating the children in our dataset all included the logical error of affirming the consequent (see Mercer (in press), this issue), as there had been no documentation of the mothers attempting to brainwash their children against their father. Similarly, no supporting evidence for maternal coaching was presented in any of the cases we studied” (p. 160).	- The allegation by Silberg and Dallam regarding “the logical error of affirming the consequent” relied on Mercer (2019a), who relied on Huff (2015), who had erroneously cited Gardner (1999b, 2004a). Silberg and Dallam said they identified ten “turned around” cases, which involved allegations of PA that were used to counteract allegations of child abuse. Thus, it is possible that some custody evaluators are making the error of “affirming the consequent” and testifying to that effect. This author contacted Silberg and asked for more specific information about the ten problematic cases; Silberg did not respond to that request.
(29) American Professional Society on the Abuse of Children (2019). APSAC published the following “Statement of Caution Regarding Use of APSAC Publications”: “It is negligent, even reckless for a judge, attorney, guardian, counselor or other professional to cite or otherwise mischaracterize this or any APSAC publication on psychological maltreatment as endorsing or even lending credence to a diagnosis or finding of ‘parental alienation.’ To find that a parent has committed psychological abuse of a child in an effort to interfere with that child’s relationship with the other parent requires direct evidence of the parent’s behavior such as significant denigration, efforts to undermine the relationship of that child with the other parent, and/or efforts to get the child to make false allegations of abuse or other extremely damaging behavior by the other parent. A child’s avoidance of a parent is not sufficient evidence of psychological abuse by either parent” (p. 1).	- The chain of misinformation regarding PA—described in this paper—culminated in a highly flawed policy statement published by APSAC. This strongly worded admonition appears to be addressing a nonexistent problem. Every PA proponent agrees that it is necessary to identify “direct evidence of the parent’s behavior,” i.e., alienating behaviors, in order to diagnose PA. The authors of the APSAC policy statement did not provide any citation from PA literature to the effect that PA can be diagnosed simply on the basis of “a child’s avoidance of a parent.”
(30) Joan S. Meier (2020). “Parental alienation, while lacking any universal definition, embodies the notion that when a child (or the primary parent) resists contact with the non-custodial parent without ‘legitimate’ reason, the preferred parent is ‘alienating’ the child, due to her own anger, hostility or pathology” (Johnston and Kelly 2004, Zaccour 2018) (p. 92).	- Meier cited Johnston and Kelly (2004), who in turn cited Gardner (2004b). However, Gardner never said that an evaluator should assume the presence of an alienating parent simply because the child manifests behaviors that are typical of PAS. Meier correctly cited Zaccour (2018), who made the same error in her article about custody cases in Quebec, Canada.
(31) Workgroup to Study Child Custody Court Proceedings Involving Child Abuse or Domestic Violence Allegations (2020). This document was prepared for the governor and legislative leaders of Maryland. The Workgroup heard testimony from Joan Meier, who said: “While there is no universal definition for parental alienation, it typically refers to a belief that a child’s behaviors, such as a fear or hostility, toward one parent are due to the malicious influence of the other parent. … Put simply, it is not appropriate for courts to rely on parental alienation as a conclusive reason for a child’s negative attitude toward a parent. Instead, courts must realize that a child may have his or her own legitimate reasons to demonstrate fear or rejection of a parent…” (p. 9).	- Meier has consistently stated the same misinformation regarding PA theory, i.e., that PA proponents automatically conclude that a child’s contact refusal is caused by alienating behaviors of the favored parent. Meier provided no source for that false information.
(32) Robert Geffner and Aileen Herlinda Sandoval (2020). “The concept of PA, when accurately used, assumes a parent is intentionally attempting to turn a child against the other parent through concerted efforts of verbally denigrating the other parent or acting in other ways to accomplish this goal” (emphasis added) (p. 28).	- Geffner and Sandoval provided no citation or other evidence for the suggestion that PA theory assumes that a parent is intentionally engaging in alienating behaviors to cause the child to turn against the other parent.
(33) Aileen Herlinda Sandoval and Robert Geffner (2020). Different constructs and labels have been used to discuss a child rejecting contact with a parent, and PAS/PAS/PA proponents assume that there is no justification for this refusal and negative reaction by the child so therefore it must be due to alienation” (emphasis added) (p. 38).	- Sandoval and Geffner provided no citation or other evidence for the statement that PA proponents assume that contact refusal is caused by alienating behaviors of the preferred parent.
(34) Janet R. Johnston and Matthew J. Sullivan (2020). Johnston and Sullivan listed “Common Erroneous Assumptions Deriving from the Single Factor Model” (emphasis added). One of the erroneous assumptions in their list was: “If a parentally alienated child exists, then the preferred parent’s alienating behavior must exist and is fueling the child’s alienation” (p. 278).	- Johnston and Sullivan provided no citation from PA literature for the “erroneous assumption” that “if a parentally alienated child exists, then the preferred parent’s alienating behavior must exist ….”
(35) Madelyn S. Milchman, Robert Geffner, and Joan S. Meier (2020). “Sadly, child custody evaluators make frequent errors in weighing abuse and alienation evidence and in interpreting protective behaviors …. Such errors also are frequently made by those who are predisposed to assume that improper PAS/PAD/PA by the child’s preferred parent is the explanation for a child’s rejection or resistance to the other parent” (emphasis added) (pp. 341–342).	- No PA proponent suggests that evaluators should assume that the preferred parent’s activities are the reason for the child’s contact refusal. Milchman et al. provided no source for that misinformation.
(36) Jean Mercer (2020a). “[Parental Alienation Belief System] supporters assert that child avoidant behavior is evidence that psychological harm has occurred” (slide 3). “Examining the Claim that Child Avoidant Behavior is Evidence of Previous and Ongoing Psychological Harm. N.B. this is the most important of all PABS claims, as it provides the rationale for custody change and prohibition of contact between the child and the preferred parent …” (slide 4). “The preferred parent is thus categorized as an abuser, even if that person’s actions are only inferred from child avoidant behavior” (emphasis added) (slide 6).	- During one Zoom presentation to members of the American Professional Society on the Abuse of Children (APSAC), Mercer repeatedly stated misinformation, i.e., that PA proponents assume or infer that the preferred parent has manifested alienating behaviors simply based on contact refusal behaviors in the child. Mercer provided no citation or other evidence that this belief has been stated or endorsed anywhere in articles, chapters, or books written by PA proponents.
(37) Thelma Moreira Marques, Isabel Narciso, and Luana Cunha Ferreira (2020). “As Mercer (2019a) recently pointed out, there is an error of logic in the assumption that the child’s resistance or contact refusal is always the result of the manipulation or persuasion of the preferred parent, who influences the child to avoid the nonpreferred parent” (emphasis added) (p. 8).	- There is no such assumption in the world literature regarding PA. These authors cited Mercer (2019a), who discussed the logical error of assuming the consequent and wrongly attributed that error to PA proponents.
(38) Lenore E. A. Walker (2020). “Sadly, the data with which alienation claims are proven is slim to none in most of these cases, with mothers losing custody twice as much as fathers” (p. 1756).	- Walker is claiming that the diagnosis of PA is made with neither evidence of contact refusal nor evidence of alienating behaviors. The article she was discussing—Meier et al. (2019)—does not make that statement.
(39) Adrienne Barnett (2020). This document was distributed to members of the British Parliament regarding important legislation that was under consideration. Barnett explained the history of PAS and wrote: “Subsequently, PAS was extended to include cases of all types in which a child refused to visit the noncustodial parent (Bruch, 2001).”	- That is a false statement regarding PA/PAS theory. Bruch’s paper (2001) made a similar false statement regarding PA/PAS theory.
(40) Jean Mercer (2021). “The ideas behind PA are implausible for a variety of reasons, but an essential issue has to do with the use of inference rather than direct observation (Milchman et al., 2020). A child’s rejection of one parent is inferred to mean that the preferred parent has acted to alienate the child, and this assumption is made without evidence that such actions occurred except possibly for statements offered by the rejected parent” (emphases added) (p. 203). “As long as PA is simply inferred from the single fact of a child avoiding a parent, there can be no meaningful evidence about the existence or nature of the PA phenomenon” (emphasis added) (p. 208).	- Mercer provided no source for the repeated false statements that PA advocates make the diagnosis of PA simply on the basis of a child’s contact refusal. There is no such assumption or inference in the world literature regarding PA that has been published since 1985. Mercer cited Milchman et al. (2020), who made the same error.

The items in this table are in chronological order. PA = parental alienation. PAS = parental alienation syndrome.

Figure 1. Frequency of cited misinformation, 1994–2020. Forty articles, documents, and presentations were identified with the same misinformation regarding parental alienation theory, published between 1994 and 2020. A large increase in the frequency of published misinformation occurred during 2019 and 2020.

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Bruch, C. S. (2001). Parental alienation syndrome and parental alienation: Getting it wrong in child custody cases. Family Law Quarterly, 35(3), 527–552.

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Gardner, R. A. (1999a). Family therapy of the moderate type of parental alienation syndrome. The American Journal of Family Therapy, 27(3), 195–212. https://doi.org/10.1080/019261899261925

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Milchman, M. S. (2017). Misogyny in NYS custody decisions with parental alienation and child sexual abuse allegations. Journal of Child Custody, 14(4), 234–259. https://doi.org/10.1080/15379418.2017.1416723

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Zaccour, S. (2018). Parental alienation in Quebec custody litigation. Les Cahiers de Droit, 59(4), 1073–1111. https://doi.org/10.7202/1055264ar

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Mercer, J. (2019a). Are intensive parental alienation treatments effective and safe for children and adolescents?Journal of Child Custody, 16(1), 67–113. https://doi.org/10.1080/15379418.2018.1557578

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Mercer, J. (2019b). Examining parental alienation treatments: Problems of principles and practice. Child and Adolescent Social Work Journal, 36(4), 351–363. https://doi.org/10.1007/s10560-019-00625-8

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Joyce, K. J. (2019). Under the microscope: The admissibility of parental alienation syndrome. Journal of the American Academy of Matrimonial Lawyers, 32(1), 53–88.

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Meier, J. S., Dickson, S., O’Sullivan, C., Rosen, L., & Hayes, J. (2019). Child custody outcomes in cases involving parental alienation and abuse allegations [George Washington University Law School Legal Theory Paper No. 2019–2056].

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