PARENTAL ALIENATION SYNDROME:
FRYE v. GARDNER IN THE FAMILY COURTS
by Jerome H. Poliacoff, Ph.D., P.A.,Cynthia L. Greene, Esq., and Laura Smith, Esq.*
Marriage and Divorce
In 1990 the marriage rate was just double the divorce rate (approximately 2.4 million marriages and 1.2 million divorces). Following the literally millions of divorces during the preceding decade, approximately 35% of the minor children in the United States were affected by the divorce of their parents.
Despite the spousal conflicts leading to divorce, almost ninety per cent of divorcing parents are able to reach a mutual agreement regarding custody and visitation with little or no intervention from the Court. Because the other ten per cent of the divorcing parents cannot agree on custody and visitation issues initially, they are likely not to be able to agree on parenting issues in the future. Courts strive to help these families by creating flexible arrangements that will hopefully work as families grow and change.
Unfortunately the adversarial nature of the system that is supposed to provide relief serves only to become an alternate forum for the expression of conflict.
For instance, Sullivan (FN1) studied sixty-one divorcing families with children over a five year period. After five years many of the parents were still fighting and nearly one third of the children continued to be subject to intense bitterness between the parents.
Children become the prize to be won or lost in what often becomes an escalating conflict. And the courts, often at a loss as to what determination to make for which children, turn to mental health experts for advice.
With increasing caseloads and limited time to assess a divorcing parent's claim for designation as either residential or responsible parent the courts have responded to simplistic accusations which cast blame on one parent in order to make it easier for the other parent to prevail.
Notable among the allegations made by counsel in representing their client's claim for "sole ownership" of the "prize" is that of "parental alienation syndrome." The popularity of such a claim has been enhanced by theprolific writing and public appearances of Richard Gardner, M.D. as originator of this "syndrome" (FN2).
In this article we will challenge both the scientific and legal legitimacy of this syndrome. After first defining "parental alienation syndrome" (PAS) we will review the criteria by which expert testimony may be accepted into evidence and explore the shortcomings of PAS under Frye and Daubert. We will then delineate the mental health expert's ethical obligation when serving as an expert before the court as it relates to PAS. We will review the relevant case law as it pertains to the admissibility of PAS before the courts. Finally we will offer alternative areas for inquiry into the source of impaired parent child relationships occurring in the context of child custody litigation.
Termination of a spousal relationship without attendant damage to the parental relationship is a difficult task. When one parent refuses to allow the other parent to be involved in the child's life, conflict ensues and a return to court becomes inevitable. Where one parent sabotages (intentionally or unintentionally) the other parent's role in the child's life or a child becomes estranged from a parent the term "parental alienation" is used.
The term has its historical roots in the common law tradition where the tort of alienation of affection was a cause of action against a third party adult who "steals" the affection of the plaintiff's spouse.
More recently Richard Gardner coined the term "Parental Alienation Syndrome" to describe the situation in which, he asserts, a child is brainwashed solely by an alienating parent's actions.
Wood (FN3) (1994) notes that in developing the PAS "the criteria Dr. Garner uses to determine whether PAS is present are essentially borrowed from and built upon his earlier ? and now widely discredited ? objective test for determining whether children were fabricating allegations of sexual abuse, the "Sex Abuse Legitimacy Scale" (SALS).
Gardner believes that PAS arises almost exclusively in the context of child custody disputes. Gardner further asserts that, while a child contributes to the development of the alienation process, the predominant source of alienation is one parent, generally the mother.
Unfortunately, again, too many courts and too many of the mental health professionals upon whom they rely have blithely accepted in toto Gardner's theoretical writings without the critical examination requisite either under the law or the ethical standards of professional psychological practice. Before accepting PAS as science in family litigation it behooves both the family practitioner and the court to have a clearer understanding of what is more hyperbole than substance.
Frye v. Daubert: A Consensus Nevertheless
Among the legal tools available to aid the court in determining the value and utility of expert testimony in deciding a particular case are the Federal Rules of Evidence and the Frye rule.
The Frye rule is derived from a 1923 Federal Court of Appeals (Frye v. United States, 293 F. 1013, 1014, D.C. Cir. 1923) decision which holds that for scientific evidence to be admissible in court it must be gathered using techniques that have gained general acceptance in their field.
In 1993 the U.S. Supreme Court issued a decision in Daubert v. Merrell Dow Pharmaceuticals, Inc. (Daubert v. Merrell Dow Pharmaceuticals, Inc., 113 S. Ct. 2786, 2792-93,1993) (hereinafter Daubert) that provided a more clear cut, albeit sometimes ambiguous, set of guidelines for the admissibility of scientific expert testimony.
In setting forth the factors that should be considered when determining if a theory or technique qualifies as scientific knowledge that will assist the trier of fact the Court did not forgo Frye. The factors enumerated inDaubert are: (a) Is the theory or technique based on methodology that can or has been tested? (b) Has the theory or technique been the subject of peer review and publication? (c) What is the known or potential rate of error? (d) Does the technique enjoy general acceptance within the scientific community? (the old Fryerule!).
The court held that the Frye rule, including general acceptance as the primary determinant of admissibility of evidence based on scientific techniques, had been superceded by the revised Federal Rules of Evidence.
Rotgers and Barrett (FN4) cogently argue that the Daubert decision (and the Frye decision before it) has "important implications for... psychologists and other health care professionals... .whose professions have taken on the mantle of science."
They point out that mental health practitioners (psychologists, psychiatrists), despite the doubtful scientific status of many theories and assessment techniques in the field, have held themselves out to the public (and to the courts) as utilizing scientifically valid theories and methods of practice and therefor should be held to the same standards by courts as other professions that have done the same. What then are the courts' standards?
In Daubert the Supreme Court sought to clarify the criteria for the determination of admissibility of expert testimony. According to Rule 702 of the Federal Rules of Evidence "If scientific, technical or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education may testify thereto in the form of an opinion or otherwise."
That the evidence must be reliable is implied by the use in Rule 702 of the term "scientific knowledge." According to the Supreme Court the term "scientific knowledge" "implies a grounding in the methods and procedures of science". In a similar vein "the word ?knowledge' connotes more than subjective belief or unsupported speculation." In any case involving scientific evidence "evidentiary reliability will be based on scientific validity."
This approach allowed, in Daubert, sound science (based on sound scientific methodology) to prevail even though it was new science and not yet widely accepted among the scientific community from which it sprang.
Writing in the Journal of the American Medical Association, Gold (FN5) and his colleagues warn that the implication for medical (or mental health) practitioners under Daubert , and Frye before it, is "first and foremost... .that there is a difference between science and pseudoscience, and that it is the judge's role to ensure that testimony offered as ?scientific' meets a minimum test of validity before it may be put to the jury".
How then does Gardner's PAS meet the standard of scientific knowledge under the criteria set forth in eitherFrye or Daubert?
(a) Is the theory or technique based on methodology that can be or has been tested?
There are many competing theories of human behavior on which mental health professionals have drawn in reaching diagnoses and treatment recommendations. There is also a large scientific literature that has addressed empirically testable predictions based on those theories.
However, many theoretical constructs are presented by clinicians as expert testimony for which there is no scientific validation. Gardner's PAS is one of these "syndrome" theories for which the scientific basis is non-existent.
Rotgers and Barrett (Id.) note that "although it is possible to identify common behavior patterns among persons who are known to have suffered traumatic experiences of various types, syndrome theory, and often the testimony based on it, goes well beyond this possibility to state that 'all' persons who suffer particular types of trauma show characteristic behaviors."
These authors go on to cite Gardner's PAS as the exemplar of "some practitioners (who) have been willing to engage in reverse logic and state that because an individual demonstrated a particular behavior pattern, trauma must have occurred." They go on to acknowledge that the fit between syndrome theories and particular legal questions is often good but, they point out, these theories have not been scientifically tested.
Referring to the exhaustive and erudite critique of PAS by Wood (Id.), they note further that the lack of scientific testing "makes any conclusions or accounts of events that are based on syndrome theories problematic. Even if the data relied upon are gathered using scientifically valid methods, if the theoretical explanation underlying the data is faulty, the data may be presented in a fashion that misleads the trier of fact."
(b) Has the theory or technique been the subject of peer review and publication?
Berliner and Conte (FN6) (1993) scathingly note "Indeed the entire scale (the SALS) and the Parental Alienation Syndrome on which it is based have never been subjected to any kind of peer review or empirical test."
Less kind have been comments such as Conte's (FN7) (Moss, D.C., 1988) when referring to the SALS "... is probably the most unscientific garbage I've seen in the field in all my time... to base social policy on something as flimsy as this is exceedingly dangerous".
Stephanie Dallam (FN8) examined Gardner's counter-claim that his work has been published in peer-reviewed journals, a list of which is provided at Gardner's website.
She reports that two publications were chapters in books, two other articles were published in a newsletter of the American Academy of Psychoanalysis, and the two remaining articles were published in legal journals ? none of these six being peer reviewed journals!
This author's exploration of Gardner's website reveals that he cites thirty (30) cases in which PAS has been introduced as evidence before a family court. A more thorough investigation reveals that one case (In the Interest of T.M.W., 553 So. 2nd 260, 262, Fla. Dist. Ct. App., 1988) is cited three times! and in fact PAS was not accepted as scientifically valid!
(c) What is the known or potential rate of error?
The known or potential rate of error refers to the psychometric properties of a test or assessment methodology. In developing a predictive measuring tool one is concerned with both the reliability and validity of the instrument or theory.
As defined in classical test theory reliability consists of the extent to which an obtained score (or value or assertion) corresponds to the "true" (or real world) score. Is what is measured being measured accurately (reliably)? Are the results consistent when the same case is examined by different evaluators? The "true" score is an abstraction that can never be known for sure, the obtained score is a statistical measurement of the combination of this unknowable score and some error variance.
The manner in which an estimate of a score's reliability is derived (parallel form, split half, test-retest, and internal consistency methods), that is, whether it yields scores on which one can rely as providing a true picture of the property being measured, have crucial implications for forensic testimony.
Validity, as classically defined, consists of the extent to which it is known what a test measures.
A test is considered to have face validity if its items have some clear and obvious relationship to the purpose of the test (if for example the test is a measure of depression we would expect to see items like "Are you feeling depressed?" as indicative of it having face validity).
A more important measure would be criterion related validity. This is a measure that consists of the relationship between a test or test score and some other measured (or known) variable.
Substantial correlation between test findings and current status, behavior or condition demonstrates concurrent validity. Substantial correlation between test findings and future events, conditions or behaviors provide evidence of their predictive validity. Finally construct validity consists of the extent to which observed relationships between test findings and present or future events, conditions or behaviors can be conceptualized in terms of a sound theoretical rationale that accounts for both the test findings and the extra-test behaviors or states.
Commenting on the poor test construction of the SALS Berliner and Conte (Id.) commented that "there are no studies which have determined if the Scale can be coded reliably. Many of the criteria a re poorly defined. There have been no scientific tests of the ability of the SALS to discriminate among cases."
In assessing the SALS criteria for reliability Campbell (FN9) (1997) notes that the SALS criteria are "vague and ill defined" and that as a result they invite a wide range of subjective opinion and therefor "Gardner's criteria cannot support expert testimony in legal proceedings".
Deed (FN10) applied Gardner's SALS (Sex Abuse Legitimacy Scale), from which PAS theory is derived, to confirmed cases of sexual abuse and found that the SALS produced inaccurate assessments.
Gardner (FN11) himself, in summing up whether PAS should be properly admitted in court, admitted that "PAS is an initial offering and cannot have pre-existing scientific validity."
(d) Does the technique enjoy general acceptance within the scientific community? (the old Fryerule!)
Gianelli (FN12) asserts that the principal justification for the Frye test is that "it establishes a method for ensuring the reliability of scientific evidence." This serves to take the responsibility of determining the validity of a scientific principle away from the trial judge and leaving the determination to experts who know most about it.
In the case of PAS Gardner has based his theory entirely upon the observation of his own patients. It is for the most part self-published which circumvents peer review, and has not attracted wide acceptance in the scientific community.
In refusing to admit PAS into evidence a Florida court (In the Interest of T.M.W., 553 So. 2nd 260, 262 Fla. Dist. Ct. App., 1988) noted that "no determination was made in the order or on the record as to general professional acceptance of the ?parental alienation syndrome' as a diagnostic tool."
The Court went on to caution that "when considering the theory of expert testimony... it is vitally important to avoid the confusion engendered by reference to syndromes... At the present time experts have not achieved consensus on the existence of a psychological syndrome... use of the word syndrome leads only to confusion, and to unwarranted and unworkable comparisons to battered child syndrome."
The Expert's Obligation
For better or worse there is an inherent conflict between the goals of lawyers and the goals of ethical experts: the legal system is adversarial, science is not. Attorneys need partisan experts to persuade the trier of fact, be it judge or jury. Lawyers, according to Champagne and his colleagues (FN13) "seemingly want articulate, partisan experts with integrity."
Sales and Shuman (FN14) argue that "to the extent that ethics governs all scientific and professional behavior ? which it does ? it is only appropriate that it become the first metric against which to judge the expert witnessing of scientists and professionals."
Sales and Shuman point out that the most obvious case of the applicability of the ethics code to expert witnessing is the obligation to be competent (FN15).
By becoming familiar with the applicable ethical standards governing the professional behavior of psychologists and psychiatrists a more reasoned judgement can be made about the admissibility of PAS in the courtroom. While we rely primarily on the ethical standards for psychologists (FN16) in the following discussion it should be apparent to the reader that these standards speak to expected ethical professional behavior of any designation when one agrees to appear as a mental health expert before the courts.
Section 1.06 Basis for Scientific and Professional Judgements calls for psychologists to "rely on scientifically and professionally derived knowledge when making scientific or professional judgements." Not having met the standards inherent in Daubert and in Frye renders PAS unable to pass muster under this brief, but indispensable, ethical dictum.
Rotgers and Barrett (Id) have made an effort to guide psychologists in their considerations concerning serving as an expert witness. They point out four standards of professional conduct that appear to be clearly applicable to psychologists' expert testimony that are specifically reinforced by the Daubert decision. These include, in addition to Standard 1.06, the following:
Standard 2.02 "Competence and Appropriate Use of Assessments and Interventions" requires psychologists to select assessment instruments on the basis of research indicating the appropriateness of the instruments for the specific issue at hand and further enjoins psychologists from misusing those instruments.
Standard 2.04 "Use of Assessment in General and With Special Populations" requires familiarity with the psychometric properties and limitations of assessment instruments used in the practice of psychology.
Standard 2.05 "Interpreting Assessment Results" requires psychologists to directly state reservations they may have about the accuracy and limitations of their assessments.
As has been noted in the section above, PAS does not meet the courts' threshold requirement to qualify as scientific. Clearly then, the offering of PAS to the courts as an explanatory construct, let alone a basis for making recommendation about the future of children's lives, does not meet the minimal set of ethical standards incumbent on experts appearing before the court.
The Courts View
While there are a few ?hold out' jurisdictions which continue to preserve the notion of alienation of affection, most states have abolished the cause of action for alienation of affection and consequently a cause of action for parental alienation has effectively been precluded. In their rejection of the construct of alienation of affection various courts have ruled in the following fashion:
The Minnesota Supreme Court, in Larson v. Dunn, 460 N.W. 2nd 39, 45-46 Minn. 1990, rejected an appellate court's creation of the "Intentional interference with custody rights" noting that "children can be devastated by divorce" and that "the law should not provide a means of escalating intrafamily warfare" but that other remedies exist when a parent or other relative interferes with custody arrangements, and that "creating a tort of this nature is the job of the legislature, not the court."
Florida courts, for instance In the Interest of T.M.W., 553 So. 2nd 260, 262, Fla. Dist. Ct. App. 1989, have noted that there has been no claim of general professional acceptance of PAS as a tool for diagnostic evaluation, and in fact that there is no consensus by experts that such a syndrome even exists.
In Bartanus v. Lis (Bartanus v. Lis, 480 A.2nd 1178, 1181, Pa. Super. Ct. 1984) the court held that a cause of action for alienation of a child's affection is not recognized in Pennsylvania. In so ruling the court quoted The Restatement (Second) of Torts para 699, "one who, without more, alienates from its parents the affections of a child, whether a minor of full age, is not liable to the child's parents."
The Missouri Court of Appeals recognized a tort of alienation of affection of a minor or adult child (R.J. v. S.L.J., 801 S.W.2nd 608, 609, Mo. Ct. App. 1991) but in ruling opined that although the mother had a moral duty not to alienate the children's affections with respect to the father, she did not have a legal duty.
Despite expert testimony by a psychologist who asserted that the situation in question was the" worst case of PAS he had ever seen," a Wisconsin Court of Appeals held that there was "limited research data" to support, as "a successful cure" for children suffering from PAS, the removal of such children from their mother's custody in affirming the trial court's refusal to transfer custody to the father (Weiderholt v. Fischer, 485 N.W. 2nd 442, 444, Wis. Ct. App. 1992).
The PAS criteria used by Gardner, as noted above, are essentially borrowed from and built upon his earlier (and now widely discredited) test for determining whether children were fabricating allegations of sexual abuse, the "Sexual Abuse Legitimacy Scale" (SAL Scale) (Id.)
The only appellate court to rule on the admissibility of the SAL Scale held it inadmissible because there was no showing that it had "some reasonable degree of recognition and acceptability among the spectrum of scientific or medical experts in the field" (Page v. Zordan, 564 So. 2nd 500, Fla. Dist. Ct. App. 1990).
Wood (Id.) very appropriately, comments that "although it might be argued that this court properly ignored the PAS testimony, the problem is that the court even admitted it at all. The mere admission of unreliable and untested testimony into evidence in the first place means that courts admitting evidence of this theory may rule on it differently, creating results that range from potentially very dangerous to inconsistent."
Finally, in her comprehensive review of PAS Wood was unable to find a single reported case where PAS testimony was introduced on behalf of the mother.
Assessing the Utility of PAS
Dallam (Id.) exhorts in her review of Gardner's theories that "all psychological evidence upon which a child's safety will turn must be subjected to empirical testing."
As we have hopefully made clear, straightforward observation, confirmed by a consensus of experts, reveals that rather than subjecting his theories to scientific review Gardner has published through his own press or in nonscientific journals. Because his theories are based on his clinical observations (not on scientific data) they should be understood in the context of his atypical views concerning parent child relations.
[For a greater explication on his theories concerning pedophila as a "part of the natural repertoire of human sexual activity" (Richard A. Gardner, M.D., True and False Allegations of Child Sex Abuse, 1992) or that child abuse allegations are "third greatest wave of hysteria" the nation has seen, following the Salem witch trials and the McCarthyite witch hunting for communists in the 1940's the reader is referred again to the very excellent reviews by Dallam (Stephanie Dallam, The Evidence for Parental Alienation Syndrome: An Examination of Gardner's Theories and Opinions, Treating Abuse Today, 1998) or Wood (Cherri L. Wood,The Parental Alienation Syndrome: A Dangerous Aura of Reliability, 1994).]
It would be far better for the courts, in their deliberations as to parental fitness when making custody determinations, to utilize the work of Benjamin D. Garber (FN17). Garber has noted that PAS theory confuses cause and effect, whereas science has demonstrated that a cause can not necessarily be inferred from an effect.
[In the realm of statistics "correlation does not imply causation." It is often noted, with great fanfare in the press, that fashion hemlines or the winning league in the Super Bowl or the World Series correlate with either a rise or fall in the Dow Jones Industrial average ? but that correlation does not imply causation!]
He cautions that it is very easy for a presumption of alienation "to take on a life of its own without proper consideration of the many alternative (and often more likely) causes of a child's distress during parental separation and divorce."
That parental conflict and the custodial parent's ability to function have profound impact onchildren's adjustment to divorce has been recognized in legal opinions. For instance, In re: Marriage of Carney (598 P. 2nd 37, Cal. 1979), the California Court recognized the child's need for stability in its primary parenting relationship.
Johnston's (FN18) research finds that where there is high conflict, or evidence of domestic violence, between the parents, children can deteriorate dramatically.
The ambivalence towards or rejection of one parent may be related to any number of factors (FN19)and not necessarily the psychopathology of one parent.
Among the many alternative factors to PAS for an expert to consider are:
- (1) developmentally normal separation problems,
- (2) deficits in the non-custodial parent's skills,
- (3) oppositional behavior,
- (4) high-conflict divorce proceedings,
- (5) other serious emotional or medical problems of one family member,
- (6) child abuse,
- (7) inappropriate, unpredictable, or violent behavior by one parent,
- (8) incidental causes, such as the child's dislike of a parent's new roommate or lover,
- (9) alienation by third parties,
- (10) the child's unassisted manipulation of one or both parents, or
- (11) fears for the absent parent's welfare.
The value of an expert's contribution to the courts' deliberations regarding children's welfare should be based on clinically sound reasoning formulated from empirically derived data that will serve the best interest of the child and not on unsubstantiated hyperbole.
1. Sullivan, Matthew J., Parental Alienation Processes in Post-Divorce Cases, Association of Family Conciliation Courts Newsletter, Summer 1997, at 4. RETURN TO TEXT
2. Gardner, Richard A. The Parental Alienation Syndrome and the Differentiation Between Fabricated and Genuine Child Sexual Abuse, 1992. RETURN TO TEXT
4. Rotgers, Frederick and Deirdre Barrett, Daubert v. Merrell Dow and Expert Testimony by Clinical Psychologists: Implications and Recommendations for Practice, Professional Psychology: Research and Practice, 1996, at 467-474. RETURN TO TEXT
5. Gold, J. A., M.J. Zaremski, E.R. Lev and D.H. Shefrin, Daubert v. Merrell Dow: The Supreme Court Tackles Scientific Evidence in the Courtroom, JAMA, 270, 2964. RETURN TO TEXT
6. Berliner, L. and J.R. Conte, Sexual Abuse Evaluations: Conceptual and Empirical Obstacles, Journal of Child Abuse and Neglect, at 111-125 (1993). RETURN TO TEXT
7. See Moss,D. C., Abuse Scale: Point System for Abuse Claims, American Bar Association Journal, (December 1, 1988). RETURN TO TEXT
8. Dallam, Stephanie, The Evidence for Parental Alienation Syndrome: An Examination of Gardner's Theories and Opinions, Treating Abuse Today, March/April 1988, at 25-34. LINK TO DALLAM ARTICLES RETURN TO TEXT
9. Campbell, T. W., Indicators of Child Sexual Abuse and Their Unreliability, American Journal of Forensic Psychology, 1997, at 5-18. RETURN TO TEXT
10. Sherman, R., Gardner's Law, The National Law Journal, 1993, August 16. RETURN TO TEXT
11. Gardner, Richard A., M.D., Evaluate Child Sex Abuse in Context, N. J.L.J., at 16 May 10, 1993. RETURN TO TEXT
12. Gianelli, Paul C., The Admissibility of Novel Scientific Evidence: Frye v. United States, a Half-Century Later, 80 Colum. L. Rev. 1197, 1205, (1980). RETURN TO TEXT
13. Champagne, A., D.W. Shuman and E. Whittaker, The use of expert witnesses in American courts,Judicature, 375 (1991). RETURN TO TEXT
14. Sales, Bruce D., and Daniel W. Shuman, Reclaiming the integrity of science in expert witnessing, Ethics and Behavior, 223 (1993). RETURN TO TEXT
15. Principle A: Competence, and Section 7.02 Forensic Assessment (b) (c) of American Psychological Association, Ethical principles of psychologists and code of conduct, American Psychologist, 1597 (1992). RETURN TO TEXT
16. American Psychological Association, Ethical principles of psychologists and code of conduct,American Psychologist, V 47, 1597, (1992). RETURN TO TEXT
17. Garber, Benjamin D., Alternatives to Parental Alienation: Acknowledging the Broader Scope of Children's Emotional Difficulties During Parental Separation and Divorce, New Hampshire Bar Journal, at 51-54 (1996). RETURN TO TEXT
18. See Johnson, Janet R., Ongoing post divorce conflict: Effects of joint custody and frequent access. Am. J. Orthopsychiatry, 576 (1989); Johnson, High conflict divorce, Future of children, 65-174 (1994); Children's adjustment in sole compared to joint custody families and principles for custody decision making, Fam. & Conciliation Cts. Rev., 415-419 (1995). RETURN TO TEXT
19. Garber, supra note 39; also see Waldren. K. H. and D. E. Joanis, Understanding and Collaboratively Treating Parental Alienation Syndrome, American Journal of Family Law, at 121-133 (1996). RETURN TO TEXT .
Jerome H. Poliacoff, Ph.D., is a child, family, and forensic psychologist in private practice in Coral Gables, Florida, and a Florida Bar certified provider of continuing legal education, including the series of seminars entitled Psychology in The Courtroom: Challenging Psychiatric and Psychological Testimony. He completed his pre-doctoral and post-doctoral training programs in Child and Adolescent Psychology at the Children's Psychiatric Centers in Miami, Florida.
A different version of the foregoing article originally appeared in The Family Law Section COMMENTATOR, Vol.XXV, No. 4, June 1999, published by The Florida Bar.
This article may be freely reprinted for noncommercial use, provided
it is reproduced intact, along with this copyright notice and author identifying information.
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