Parental alienation syndrome

Parental alienation syndrome (abbreviated as PAS) is a term coined by Richard A. Gardner in the early 1980s to refer to what he describes as a disorder in which a child, on an ongoing basis, belittles and insults one parent without justification, due to a combination of factors, including indoctrination by the other parent (almost exclusively as part of a child custody dispute) and the child's own attempts to denigrate the target parent.[1] Gardner introduced the term in a 1985 paper, describing a cluster of symptoms he had observed during the early 1980s.[1]

Parental alienation syndrome is not recognized as a disorder by the medical or legal communities and Gardner's theory and related research have been extensively criticized by legal and mental health scholars for lacking scientific validity and reliability.[2][3][4][5][6] However, the separate but related concept of parental alienation, the estrangement of a child from a parent, is recognized as a dynamic in some divorcing families.[2][7][8] Psychologists differentiate between parental alienation and parental alienation syndrome by linking parental alienation with behaviors or symptoms of the parents, while parental alienation syndrome is linked to hatred and vilification of a targeted parent by the child.[9]

The admissibility of PAS has been rejected by an expert review panel and the Court of Appeal of England and Wales in the United Kingdom and Canada's Department of Justice recommends against its use. PAS has appeared in some family court disputes in the United States.[10][11] Gardner portrayed PAS as well accepted by the judiciary and having set a variety of precedents, but legal analysis of the actual cases indicates that as of 2006 this claim was incorrect.[6]

No professional association has recognized PAS as a relevant medical syndrome or mental disorder, and it is not listed in the International Statistical Classification of Diseases and Related Health Problems of the WHO or in the American Psychiatric Association's Diagnostic and Statistical Manual of Mental Disorders (DSM).

Initial description

Parental alienation syndrome was a term coined by child psychiatrist Richard A. Gardner drawing upon his clinical experiences since the early 1980s.[1] The concept of one parent attempting to separate their child from the other parent as punishment or part of a divorce have been described since at least the 1940s,[2][8] but Gardner was the first to define a specific syndrome. In a 1985 article, he defined PAS as "...a disorder that arises primarily in the context of child-custody disputes. Its primary manifestation is the child's campaign of denigration against the parent, a campaign that has no justification. The disorder results from the combination of indoctrinations by the alienating parent and the child's own contributions to the vilification of the alienated parent"[1] also stating that the indoctrination may be deliberate or unconscious on the part of the alienating parent.[12][13] PAS was originally developed as an explanation for the increase in the number of reports of child abuse in the 1980s.[14][15] Gardner initially believed that parents (usually mothers) made false accusations of child abuse and sexual abuse against the other parent (usually fathers) in order to prevent further contact between them.[16][17] While Gardner initially described the mother was the alienator in 90% of PAS cases, he later stated both parents were equally likely to alienate.[14][18][19] He also later stated that in his experience accusations of sexual abuse were not present in the vast majority of cases of PAS.[15]

Characteristics

Gardner described PAS as a preoccupation by the child with criticism and deprecation of a parent.[20] Gardner stated that PAS occurs when, in the context of child custody disputes, one parent deliberately or unconsciously attempts to alienate a child from the other parent.[21] According to Gardner, PAS is characterized by a cluster of eight symptoms that appear in the child. These include a campaign of denigration and hatred against the targeted parent; weak, absurd, or frivolous rationalizations for this deprecation and hatred; lack of the usual ambivalence about the targeted parent; strong assertions that the decision to reject the parent is theirs alone (the "independent-thinker phenomenon"); reflexive support of the favored parent in the conflict; lack of guilt over the treatment of the alienated parent; use of borrowed scenarios and phrases from the alienating parent; and the denigration not just of the targeted parent but also to that parent's extended family and friends.[13][18][22] Despite frequent citations of these factors in scientific literature, "the value ascribed to these factors has not been explored with professionals in the field."[23]

Gardner and others have divided PAS into mild, moderate and severe levels. The number and severity of the eight symptoms displayed increase through the different levels. The recommendations for management differ according to the severity level of the child's symptoms. While a diagnosis of PAS is made based on the child's symptoms, Gardner stated that any change in custody should be based primarily on the symptom level of the alienating parent.[24] In mild cases, there is some parental programming against the targeted parent, but little or no disruption of visitation, and Gardner did not recommend court-ordered visitation. In moderate cases, there is more parental programming and greater resistance to visits with the targeted parent. Gardner recommended that primary custody remain with the programming parent if the brainwashing was expected to be discontinued, but if not, that custody should be transferred to the targeted parent. In addition, therapy with the child to stop alienation and remediate the damaged relationship with the targeted parent was recommended. In severe cases, children display most or all of the 8 symptoms, and will refuse steadfastly to visit the targeted parent, including threatening to run away or commit suicide if the visitation is forced. Gardner recommended that the child be removed from the alienating parent's home into a transition home before moving into the home of the targeted parent. In addition, therapy for the child is recommended.[1][22][24] Gardner's proposed intervention for moderate and severe PAS, including court-ordered transfer to the alienated parent, fines, house arrest, incarceration, have been critiqued for their punitive nature towards the alienating parent and alienated child, and for the risk of abuse of power and violation of their civil rights.[25][26] With time, Gardner revised his views and expressed less support for the most aggressive management strategies.[25]

Reception

Gardner's original formulation, which labeled mothers almost exclusively as the alienating parent, was endorsed by fathers' rights groups, as it allowed fathers to explain the reluctance of their children to visit them and assign blame to their former wives.[25][27] In contrast, women's groups criticized the syndrome, concerned that it permitted abusers to claim that allegations of abuse by mother or child were reflective of brainwashing.[25] Gardner himself emphasized that PAS only applied in situations where there was no actual abuse or neglect had not occurred,[6][28] but by 1998, noted an increase in the awareness of PAS had led to an increase in its misapplication as an exculpatory legal maneuver.[12]

PAS has been cited in high-conflict divorce and child custody cases, particularly as a defense against accusations of domestic violence or sexual abuse.[4][22] The status of the syndrome, and thus its admissibility in the testimony of experts, has been the subject of dispute about the extent to which PAS has been accepted by the professionals in the field, as well as a scientific methodology that is testable, has been tested, has a known error rate, has been published and is peer-reviewed.[22]

PAS has not been accepted by experts in psychology, child advocacy or the study of child abuse[5] or legal scholars.[6] PAS has been extensively criticized by members of the legal and mental health community, who state that PAS should not be admissible in child custody hearings based on both science and law.[4][5][6][22][29]

PAS is not recognized by the American Medical Association or the American Psychiatric Association.[6][15][16][30] The American Psychological Association declined to give a position on PAS, but raised concerns over its lack of supporting data and how the term is used.[31] The APA's 1996 Presidential Task Force on Violence and the Family expressed concern that custody evaluators use PAS as a means of giving custody to fathers despite a history of violence, a concern shared by other commentators.[4][32][33] The United States National Council of Juvenile and Family Court Judges rejected PAS, recommending it not be used for the consideration of child-custody issues.[27]

Absence from the DSM

PAS is not included in the American Psychiatric Association's Diagnostic and Statistical Manual of Mental Disorders (DSM-IV).[6][15][16][30] Gardner and others lobbied for its inclusion in the DSM-V revision.[34][35] In 2001, Gardner argued that when the DSM-IV was released, there was insufficient research to include PAS, but since then, there have been enough scientific articles and attention to PAS that it merited being taken seriously.[34] A survey of American custody evaluators, published in 2007, found that half of the respondents disagreed with its inclusion, while a third thought it should be.[13] A related formulation, named parental alienation disorder, has been proposed, suggesting that inclusion of PAS in the DSM-5 would promote research and appropriate treatment, as well as reduce misuse of a valid and reliable construct.[2] In December 2012, the American Psychiatric Association announced that PAS would not be included in the DSM-V revision.[36] However, there are now diagnoses included in DSM-V that reflect the mental illness of this phenomenon, in particular parent-child relational problem and child affected by parental relationship distress, even if the exact term parental alienation is not included in DSM-V.[37]

Scientific status

Gardner's formulation of PAS is critiqued as lacking a scientific basis,[38][39][40] and as a hypothesis whose proponents have failed to meet the scientific burden of proof to merit acceptance.[6][38][40][41][42] The first publications about PAS were self-published and not peer reviewed,[8] and though subsequent articles have been published in peer reviewed journals, most have consisted of anecdotal evidence in the form of case studies;[43][44] in addition, the limited research into PAS has lacked evidence of its validity and reliability.[4][5] The lack of objective research and replication, falsifiability, and independent publication has led to claims that PAS is pseudoscience or junk science.[3][38][39] Proponents of PAS concur that large scale systematic controlled studies into PAS's validity and reliability are required,[8][13][45] supplementing a single small study in 2004 which suggested practitioners could come to a consensus based on written reports.[29]

The theoretical foundation of PAS has been described as incomplete, simplistic and erroneous for ignoring the multiple factors (including the behaviors of the child, parents and other family members) that may contribute to parental alienation, family dysfunction and a breakdown in attachment between a parent and a child.[8][14][32][43][46] In this view, PAS confuses a child's developmental reaction to a divorce with psychosis, vastly overstates the number of false allegations of child sexual abuse, ignores the scientific literature suggesting most allegations of child sexual abuse are well founded and thus well-meaning efforts to protect a child from an abusive parent, exaggerates the damaging effects of parental alienation on children and proposes an unsupported and endangering remedy for PAS.[4][29] Concern has been expressed that PAS lacks adequate scientific support to be considered a syndrome and that Gardner has promoted PAS as a syndrome based on a vague clustering of behaviors.[8][16] Despite concerns about the validity of testimony regarding PAS, it has been inappropriately viewed as reliable by family court judges.[6] Proponents of PAS and others agree that using the designation of syndrome may be inappropriate as it implies more scientific legitimacy than it currently deserves.[20][25][45]

While PAS is not accepted as a syndrome, parental alienation is a somewhat less controversial dynamic that has also appeared in the mental health and legal literature.[23][25] Since Gardner proposed PAS, other researchers in the field have suggested focusing less on diagnosing a syndrome and more on what has been described as the "alienated child," and the dynamics of the situation that have contributed to the alienation.[14][25]

Clinical status

PAS has been criticized for making clinical work with children who are alienated more confusing[8] and for labeling children with a mental diagnosis who may react angrily to their parents' separation or divorce.[47] Gardner's analysis has been criticized for inappropriately assigning all responsibility of the child's behavior to one parent when the child's behavior is oftentimes, but not always, the result of a dynamic in which both parents and the child play a role.[26][46]

Gardner disagreed with criticism of PAS as overly simplistic, stating that while there are a wide variety of causes on why a child may become alienated from a parent, the primary etiological factor in cases of PAS is the brainwashing parent, and that otherwise, there is no PAS.[12] Gardner also stated that those initially critical of PAS for being a caricature were not directly involved with families in custody disputes and that criticisms of this nature faded by the late 1980s because the disorder was widespread.[1]

Gender

PAS has been criticized by for being sexist, being used by fathers to marginalize legitimate fears and concerns about abuse, and women's groups and others oppose the legitimacy of PAS as a danger to children.[32] After his initial publications, Gardner revised his theory to make fathers and mothers equally likely to alienate or be indoctrinators and disagreed that recognition of PAS is sexist. Gardner later indicated he believed men were equally likely to be PAS indoctrinators.[12] Studies of children and adults labelled as suffering from PAS have suggested that mothers were more likely than fathers to be the alienator.[13]

In courts

Canada

Early Canadian court cases accepted expert opinions about PAS, used the term "syndrome" and concurred with Gardner's theory that only one parent was fully responsible for it. Gardner testified in one case (Fortin v. Major, 1996) but the court did not accept his opinion, concluding that the child was not alienated based on the evaluation of a court-appointed expert who, unlike Gardner, had met with the family members.[25] More recent cases, while accepting the concept of alienation, have noted the lack of recognition in the DSM-IV, and have generally avoided "syndrome" terminology, emphasizing that changes in custody are stressful for the child and should only occur in the most severe cases.[25] A 2006 research report by the Canadian Department of Justice described PAS as "empirically unsupported" and favored a different framework for dealing with issues of alienation that has more research support.[48] Decisions about possible parental alienation are considered a legal decision, to be determined by the judge based on the facts of the case, rather than a diagnosis made by a mental health professional. There is recognition that rejection of a parent is a complex issue, and that a distinction must be made between pathological alienation and reasonable estrangement.[25]

United Kingdom

In the United Kingdom, the admissibility concerning the evaluation of PAS was rejected both in an expert review,[49] and by the Court of Appeal.[10][11]

United States

PAS has been cited as part of the child custody determination process in the United States.[10] Based on the evaluation of PAS, courts in the US have awarded sole custody to some fathers.[6] PAS has been challenged under the Frye test, to evaluate if it has been accepted by the scientific community.[6][50] Despite Gardner claiming PAS was generally accepted by the scholarly community and passed the Frye test in two states,[12] a 2006 analysis of court cases involving PAS and cited by Gardner concluded that these decisions did not set legal precedent, that PAS is viewed negatively in most legal scholarship, and that Gardner's writings do not support the existence of PAS. Of sixty-four precedent-bearing cases, only two decisions, both in New York State and both in criminal courts actually set precedents. Both held PAS inadmissible and one case found that PAS failed the Frye test as the appropriate professional community did not generally accept; this decision was upheld in an appellate court. Gardner listed fifty cases on his website that he claimed set precedents that made PAS admissible, but none actually did; forty-six set no precedents or did not discuss admissibility and the remaining four were problematic. One case stated that PAS passed the Frye test, but the appeal did not discuss the Frye test and actually "[threw] out the words 'parental alienation syndrome'" and focused on the "willingness and ability of each parent to facilitate and encourage a close and continuing relationship between the parents and the child". In the second case, the appellate court did not discuss PAS; the third case specifically chose not to discuss the admissibility of PAS and the fourth made no decision on PAS.[6]

In some U.S. jurisdictions, child support has been suspended in cases of parental alienation. For example, in New York in Matter of Robert Coull v. Pamela Rottman, No. 2014-01516, 2015 N.Y. App. Div. LEXIS 6611 (September 2, 2015), where the father was prevented from seeing his son by the child's mother through a "pattern of alienation", child support was suspended.[51]

See also

References

  1. 1 2 3 4 5 6 Gardner, RA (2001). "Parental Alienation Syndrome (PAS): Sixteen Years Later". Academy Forum. 45 (1): 10–12. Retrieved 2009-03-31.
  2. 1 2 3 4 Bernet, W (2008). "Parental Alienation Disorder and DSM-V". The American Journal of Family Therapy. 36 (5): 349–366. doi:10.1080/01926180802405513.
  3. 1 2 Faller, KC (1998). "The parental alienation syndrome: What is it and what data support it?" (pdf). Child Maltreatment. 3 (2): 100–115. doi:10.1177/1077559598003002005.
  4. 1 2 3 4 5 6 Bruch, CS (2001). "Parental Alienation Syndrome and Parental Alienation: Getting It Wrong in Child Custody Cases" (pdf). Family Law Quarterly. 35 (527): 527–552.
  5. 1 2 3 4 Wood, CL (1994). "The parental alienation syndrome: a dangerous aura of reliability". Loyola of Los Angeles Law Review. 29: 1367–1415. Retrieved 2008-04-12.
  6. 1 2 3 4 5 6 7 8 9 10 11 12 Hoult, JA (2006). "The Evidentiary Admissibility of Parental Alienation Syndrome: Science, Law, and Policy". Children's Legal Rights Journal. 26 (1).
  7. ↑ Rohrbaugh, Joanna Bunker (2008). A comprehensive guide to child custody evaluations: mental health and legal perspectives. Berlin: Springer. pp. 399–438. ISBN 0-387-71893-1.
  8. 1 2 3 4 5 6 7 Warshak, RA (2001). "Current controversies regarding parental alienation syndrome" (pdf). American Journal of Forensic Psychology. 19 (3): 29–59.
  9. ↑ Darnall, D. (1997). "Symptoms of Parental Alienation". PsyCare
  10. 1 2 3 Fortin, Jane (2003). Children's Rights and the Developing Law. Cambridge University Press. pp. 263. ISBN 9780521606486.
  11. 1 2 Bainham, Andrew (2005). Children: The Modern Law. Jordans. pp. 161. ISBN 9780853089391.
  12. 1 2 3 4 5 Gardner, Richard (2004). "Commentary on Kelly and Johnston's The Alienated Child: A Reformulation of Parental Alienation Syndrome" (pdf). Family Court Review. 42 (4): 611–21. doi:10.1177/1531244504268711.
  13. 1 2 3 4 5 Baker, AJL (2007). "Knowledge and Attitudes About the Parental Alienation Syndrome: A Survey of Custody Evaluators". American Journal of Family Therapy. 35 (1): 1–19. doi:10.1080/01926180600698368.
  14. 1 2 3 4 Jaffe, PG; Lemon NKD; Poisson SE (2002). Child Custody & Domestic Violence. SAGE Publications. pp. 52–54. ISBN 9780761918264.
  15. 1 2 3 4 Dallam, SJ (1999). "The Parental Alienation Syndrome: Is It Scientific?". In St. Charles E; Crook L. Expose: The failure of family courts to protect children from abuse in custody disputes. Our Children Our Children Charitable Foundation.
  16. 1 2 3 4 Caplan, PJ (2004). "What is it that's being called Parental Alienation Syndrome". In Caplan PJ; Cosgrove L. Bias in psychiatric diagnosis. Rowman & Littlefield. pp. 62. ISBN 9780765700018.
  17. ↑ Brown, T; Renata A (2007). Child Abuse and Family Law: Understanding the Issues Facing Human Service and Legal Professionals. Allen & Unwin. pp. 11–12. ISBN 9781865087313.
  18. 1 2 Gardner, RA (2002). "Denial of the Parental Alienation Syndrome Also Harms Women". American Journal of Family Therapy. 30 (3): 191–202. doi:10.1080/019261802753577520.
  19. ↑ Baker AJL (2007). Adult children of parental alienation syndrome: breaking the ties that bind. New York: W. W. Norton & Company. ISBN 0-393-70519-6.
  20. 1 2 Ackerman, Ph.D, Marc J. (2002). Clinician's Guide to Child Custody Evaluations. John Wiley and Sons,. pp. 73–82. ISBN 9780471150916.
  21. ↑ Jaffe, Peter G.; Lemon, Nancy K. D.; Poisson, Samantha E. (2002). Child Custody & Domestic Violence. SAGE Publications. pp. 52–54. ISBN 9780761918264.
  22. 1 2 3 4 5 Walker, LEA; Brantley KL; Rigsbee JA (2004). "A Critical Analysis of Parental Alienation Syndrome and Its Admissibility in the Family Court". Journal of Child Custody. 1 (2): 47–74. doi:10.1300/J190v01n02_03.
  23. 1 2 Bow, JN; Gould JW; Flens JR (2009). "Examining Parental Alienation in Child Custody Cases: A Survey of Mental Health and Legal Professionals". The American Journal of Family Therapy. 37 (2): 127–145. doi:10.1080/01926180801960658.
  24. 1 2 Gardner, Richard A. (2006). "Introduction". In Gardner, Richard A.; Sauber, S. Richard; Lorandos, Demosthenes. The International Handbook of Parental Alienation Syndrome: Conceptual, Clinical And Legal Considerations. Charles C. Thomas. pp. 5–11. ISBN 978-0398076474.
  25. 1 2 3 4 5 6 7 8 9 10 Bala, Nicholas; Fidler, Barbara-Jo; Goldberg, Dan; Houston, Claire (2007). "Alienated Children and Parental Separation: Legal Responses in Canada's Family Courts". Queen's Law Journal. 38: 79–138.
  26. 1 2 Johnston, JR; Kelly JB (2004). "Rejoinder to Gardner's Commentary on Kelly and Johnston's 'The Alienated Child: A Reformulation of Parental Alienation Syndrome'". Family Court Review. 42 (4): 622–628. doi:10.1111/j.174-1617.2004.tb01328.x.
  27. 1 2 Ottaman, A; Lee R (2008). "Fathers' rights movement". In Edleson JL; Renzetti, CM. Encyclopedia of Interpersonal Violence. SAGE Publications. pp. 252. ISBN 978-1412918008.
  28. ↑ Gardner, RA (1998). "Recommendations for Dealing with Parents who Induce a Parental Alienation Syndrome in their Children". Journal of Divorce & Remarriage. 28 (3/4): 1–21. doi:10.1300/J087v28n03_01.
  29. 1 2 3 Drozd, L (2009). "Rejection in cases of abuse or alienation in divorcing families". In Galatzer-Levy RM; Kraus L; Galatzer-Levy J. The Scientific Basis of Child Custody Decisions, 2nd Edition. John Wiley & Sons. pp. 403–416. ISBN 9780470038581.
  30. 1 2 Comeford, L (2009). "Fatherhood Movements". In O'Brien J. Encyclopedia of Gender and Society. 1. SAGE Publications. pp. 285. ISBN 9781412909167.
  31. ↑ "APA Statement on Parental Alienation Syndrome". Washington, DC: American Psychological Association. 1996. Retrieved 2009-03-31.
  32. 1 2 3 Sparta, SN; Koocher GP (2006). Forensic Mental Health Assessment of Children and Adolescents. Oxford University Press. pp. 83, 219–221. ISBN 9780195145847.
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  34. 1 2 Gardner, RA (2002-10-06). PAS and the DSM-5: A Call for Action. Men's News Daily. Archived from the original on 2003-12-20. Retrieved 2010-03-20.
  35. ↑ Rotstein, Gary (February 15, 2010). "Mental health professionals getting update on definitions". Pittsburgh Post-Gazette. Retrieved 2 March 2010.
  36. ↑ "American Psychiatric Association Board of Trustees Approves DSM-5-Diagnostic manual passes major milestone before May 2013 publication". American Psychiatric Association. 1 December 2012.
  37. ↑ Slatton, Traci (May 26, 2015). "Lost Parents: When High Conflict Divorce Leads to Parental Alienation". Huffington Post. Retrieved 2015-06-06.
  38. 1 2 3 Emery, RE (2005). "Parental Alienation Syndrome: Proponents bear the burden of proof" (pdf). Family Court Review. 43 (1): 8–13. doi:10.1111/j.1744-1617.2005.00002.x.
  39. 1 2 Bond, Richard (2008). "The Lingering Debate Over the Parental Alienation Syndrome Phenomenon". 4 (1). Journal of Child Custody: 37–54.
  40. 1 2 Martindale, David; Gould, Jonathan W. (2007). The Art and Science of Child Custody Evaluations. New York: The Guilford Press. ISBN 1-59385-488-9.
  41. ↑ Houchin, TM; Ranseen, J; Hash, PAK; Bartnicki, DJ (2012). "The Parental Alienation Debate Belongs in the Courtroom, Not in DSM-5". Journal of the American Academy of Psychiatry and the Law. 40 (1): 127–131.
  42. ↑ Pepitona, M. Brianna; Alvis, Lindsey J.; Allen, Kenneth; Logid, Gregory (2012). "Is Parental Alienation Disorder a Valid Concept? Not According to Scientific Evidence. A Review of Parental Alienation, DSM-5 and ICD-11 by William Bernet.". Journal of Child Sexual Abuse. 21 (12): 244–253. doi:10.1080/10538712.2011.628272.
  43. 1 2 Ackerman MJ (2001). Clinician's guide to child custody evaluations. New York: John Wiley & Sons. pp. 73–82. ISBN 0-471-39260-X.
  44. ↑ Ragland, ER; Fields H (2003). "Parental Alienation Syndrome: What Professionals Need to Know Part 1 of 2 Update". American Prosecutors Research Institute Newsletter. 16 (6).
  45. 1 2 Warshak, Richard A. "Bringing sense to Parental Alienation: A Look at the Disputes and the Evidence]" (PDF). Family Law Quarterly. 37 (2): 273–301.
  46. 1 2 Waldron, KH; Joanis DE (1996). "Understanding and Collaboratively Treating Parental Alienation Syndrome". American Journal of Family Law. 10: 121–133.
  47. ↑ Walker, Lenore E.; Shapiro, David L. (2010). "Parental Alienation Disorder: Why Label Children with a Mental Diagnosis?". Journal of Child Custody. 7 (4): 266–286. doi:10.1080/15379418.2010.521041.
  48. ↑ Jaffe, PG; Crooks CV; Bala N (2006). Making Appropriate Parenting Arrangements in Family Violence Cases: Applying the Literature to Identify Promising Practices (pdf). Department of Justice. Retrieved 2009-05-05.
  49. ↑ Sturge, C; Glaser D (2000). "Contact and domestic violence – the experts' court report". Family Law. 615.
  50. ↑ Myers, John E. B. (2005). Myers on evidence in child, domestic, and elder abuse cases. Gaithersburg, Md: Aspen Publishers. pp. 415. ISBN 0-7355-5668-7.
  51. ↑ Denney, Andrew (9 September 2015). "Father Not Obligated to Pay Child Support, Panel Finds". New York Law Journal.

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