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The question whether courts should order children with parental alienation syndrome (PAS) to visit/reside with the alienated parent has been a significant source of controversy among legal and mental health professionals. This article describes 99 PAS cases in which the author has been directly involved, cases in which he has concluded that the court should order visitation with or transfer primary residential custody to the alienated parent. The outcome when such orders were implemented (N=22) will be compared with the outcome when this recommendation was not followed (N=77). This is the definition of the parental alienation syndrome that I have used since my first publication on the disorder in 1985: The parental alienation syndrome (PAS) is a disorder that arises primarily in the context of child-custody disputes. Its primary manifestation is the child's campaign of denigration against a parent, a campaign that has no justification. It results from the combination of a programming (brainwashing) parent's indoctrinations and the child's own contributions to the vilification of the target parent. When true parental abuse and/or neglect is present, the child's animosity may be justified, and so the parental alienation syndrome explanation for the child's hostility is not applicable. There are 8 primary symptoms and 3 types of PAS and these are delineated in Table 1. It is important to note that the level of PAS diagnosis is based on the children's behavior and not on the degree of indoctrination to which the child may have been subjected. Indoctrinators can also be divided into mild, moderate, and severe categories, but the delineation is not as well defined as that of the child. Furthermore, severe level alienators may only be 'successful' in producing mild or moderate levels of PAS in their children because the strong, healthy bonding of the alienated parent has served as an antidote to the development of the severe level of PAS in the child. The PAS arises in the context of child-custody litigation and the approaches to its alleviation, with rare exception, involve the utilization of courts of law. The mental health professionals'
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