Today is a win for Domestic Violence Victims Around the World! Weinstein to Jail and WHO Denies PAS
Harvey Weinstein is headed to jail on rape charges and The World Health Organization declares that Parental Alienation Syndrome (PAS) does not exist as a mental health diagnosis and is declassified. On 15 February 2020, the WHO declared that it had removed this pseudo-scientific concept of PAS from its index and classification.
The Italian members of the Facebook group PAS: informazioni e disinformazione were the first to spread the information. They spotted a comment from a WHO team, Team3 WHO, on the page of the Classification devoted to Psychological maltreatment, in response to a remark reminding that parental alienation has no scientific basis.
Team3 WHO declares:
"Parental alienation has been removed from the ICD-11 classification as it is a judicial term and issue. Its inclusion for coding purposes in the ICD-11 will not contribute to valid or meaningful health statistics."
Collective Memo of Concern to: World Health Organization
RE: Inclusion of “Parental Alienation” as a “Caregiver-child relationship problem” CodeQE52.0 in the International Classification of Diseases 11th Revision (ICD-11)From: 352 Concerned Family Law Academics, Family Violence Experts, Family Violence Research Institutes, Child Development and Child Abuse Experts, Children’s Rights Networks and Associations and 764 concerned individuals
1Date: July 10, 2019Introduction to the Inclusion ProblemIt has recently come to our collective attention that the World Health Organization is considering the addition of “parental alienation” (PA) as a “caregiver-child relationship problem” in ICD-11, the International Classification of Diseases 11th Revision. We are surprised by the lack of prior consultation in connection with gender equality issues associated with the concept and are deeply concerned about this proposal from a women’s safety and child development, health and safety point of view, as well as from research and science perspectives.We are requesting removal of all references to “parental alienation” and related concepts in ICD-11 for the reasons set out below. Our research and experience in court has demonstrated that parental alienation, which lacks credibility, is frequently employed to divert attention from domestic violence and abuse and other evidence relevant to the best interests of the child.Empirically verified problems associated with the application of parental alienation theory, discussed in Part Two, include: Limited support for the concept in scientific research on children Gender bias in the application and effects of parental alienation claims Deflection of attention from scrutiny of parenting practices and parent-child relationships infavor of assuming primary-care parental blame when children have poor relationships with theother parent Deflection of attention from scrutiny of child risk and safety factors in family violence cases Imposition of equal time, joint custody presumptions or equal shared parental responsibility1 Linda C Neilson, Professor Emerita, University of New Brunswick, Canada, and Research Fellow of the Muriel McQueen Fergusson Centre for Family Violence Research composed this memo with the support and assistance of Joan Meier, Professor of Law, George Washington University Law School and Legal Director, Domestic Violence Legal Empowerment and Appeals Project (DV LEAP); Elizabeth Sheehy, Professor Emerita, F.R.S.C., O.O., University of Ottawa, Faculty of Law; Margaret Jackson, Professor Emerita, Director of the FREDA Centre on Violence Against Women and Children; Prof. Ruth Halperin-Kaddari, Professor at Bar-Ilan University Faculty of Law, Israel, Founding Head of the Rackman Center for the Advancement of Women at BIU and former Vice-Chair of CEDAW; Susan Boyd, Professor Emerita F.R.S.C., Peter A. Allard School of Law, University of British Columbia; Peter Jaffe, PhD, Psychologist & Professor, Academic Director, Center for Research and Education on Violence Against Women and Children, Western University, London ON, Canada; and Simon Lapierre, Full Professor, School of Social Work, University of Ottawa.
📷 📷 📷 📷 📷 📷 Deflection of attention from thorough analysis of the best interests of children criteria The silencing of women and children such that evidence of family violence and of negativeparenting is not presented The discounting of the perspectives of children and the failure to protect children from parentalabuse, contrary to the internationally recognized rights of children set out in the United NationsConvention on the Rights of the Child Inappropriate assignment of parental blame for normal adolescent behavior Deflection of attention from studies that demonstrate child resistance to contact and child harmare better explained by factors other than those proposed by parental alienation theory Emerging evidence that parental alienation “remedies” are harming many children Negative effect of the theory on evidence and on legal responsibilities to assess children’s bestinterests and safety The undermining of knowledge about how family violence harms children and what is neededfor their safety and well-being.PART TWO: Discussion. The parental alienation concept is not supported by credible scientific research on children.Discussion: As the Amici brief to the Court of Appeals for the State of New York (March 22, 2019) associated with E.V. (Anonymous) v R.V. (Anonymous) and G.V. (Anonymous) Westchester Country Clerk’s Index No. 10602/2007, states:Parental alienation, while lacking a universal clinical or scientific definition, generally refers to the presumption that a child’s fear or rejection of one parent (typically the non- custodial parent), stems from the malevolent influence of the preferred (typically custodial) 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 (or programming), regardless of the child’s own experience. There is little or no scientific support for either premise, and both derive from PAS, which has itself been roundly debunked by scientific and professional authorities.2Vigorous debate and controversy surround the validity of “parental alienation” “diagnoses” and the assessment tools and remedies associated with it.3 While some authors contend that the concept has2 PAS stands for Parental Alienation Syndrome, a controversial concept proposed by child psychiatrist Richard A Gardner that resulted in family courts removing numerous children from the primary care of protective mothers. The concept was soundly refuted on grounds of gender bias, harm to children, and lack of scientific credibility in the mid 1980s. It then fell into disuse. The same concept resurfaced in the mid 2000s largely as a result of Dr. Amy J. L. Baker’s interviews in the United States with forty adults who responded to an advertisement, who claimed to have been alienated from a parent when they were children. Blatant anti women and children terminology found in Gardner’s earlier work has been removed (although gender bias and the undermining of the views of children have remained) and the word “syndrome” was omitted, presumably in order to avoid the need for scientific proof of a mental health condition. Despite questionable research foundations, the concept spread rapidly and is now being applied in many parts of the world.3 Julie Doughty et al., “Parental alienation: in search of evidence”  Fam Law 1304 [hereafter Doughty et al. (2018a)]; Julie Doughty et al., Review of research and case law on parental alienation (Cardiff: Welsh Government, 2018) [hereafter Doughty et al. (2018b)]: L. Drozd, “Rejection in cases of abuse or alienation in divorcing families” in
📷 📷 📷 📷 📷📷 📷 📷 📷demonstrated scientific validity,4 many tenured academic researchers, child experts and experts in the domestic and family violence fields disagree. References to published criticisms of parental alienation theory by internationally respected experts are listed in footnote 5.5 It is important to note that many of the assertions of validity have been advanced by individuals who offer or have offered alienation “reunification therapy” for economic gain or who are expert witnesses paid to testify in custody cases.6Concerns about parental alienation theory that have been validated empirically by researchers who do not have vested economic or personal interests in parental alienation remedie, include: 1) Concerns about research credibility,7 limited evidence of representativeness of study samples, small sample sizes,8 absence of longitudinal research,9 and most importantly, lack of research controls to assess for and rule out alternative explanations for child resistance to contact andRM Galatzer-Levy, L Kraus & J Galatzer-Levy, eds, The Scientific Basis of Child Custody Decisions (2nd ed) (Hoboken, NJ: John Wiley & Sons, 2009) 403; C.S. Bruch, “Parental Alienation Syndrome and Parental Alienation: Getting It Wrong in Child Custody Cases” (2001) 35 Family Law Quarterly 527; M.S. Pignotti, “Parental alienation syndrome (PAS): unknown in medical settings, endemic in courts” (2013) 104:2 Pub Med 54; Holly Smith,“Parental Alienation Syndrome: Fact or Fiction? The Problem With Its Use in Child Custody Cases” (2016) 11 Mass. L. Rev. 64; C. Dalton et al., Navigating Custody and Access Evaluation in Domestic Violence Cases (Reno, NV: National Council of Juvenile and Family Court Judges, 2006); Hon. Jerry Bowles et al., A Judicial Guide to Child Safety in Custody Cases (Reno, NV: National Council of Juvenile and Family Court Judges, 2009); Joan Meier, “A Historical Perspective on Parental Alienation Syndrome and Parental Alienation” (2009) 6 Journal of Child Custody 232; Toby Kleiman, “Family court ordered ‘reunification therapy’: junk science in the guise of helping parent/child relationships?” (2017) 14:4 Journal of Child Custody 295; Linda C Neilson, Parental Alienation Empirical Analysis: Child Best Interests or Parental Rights? (Fredericton: Muriel McQueen Fergusson Centre for Family Violence; Vancouver: FREDA Centre for Research on Violence Against Women and Children, 2018).4 For example, William Bernet & Amy J.L. Baker, “Parental Alienation, DSM-5 , and ICD-11: Response to Critics” (2013) 41:1 Journal of the American Academy of Psychiatry and the Law 98; Richard Warshak, “Current Controversies Regarding Parental Alienation Syndrome” (2001) 19:3 American Journal of Forensic Psychology 29; Stanley Clawar & Brynne Rivlin, Children Held Hostage (2nd ed) (Chicago: American Bar Association, 2013).5 Published comments critical of parental alienation theory by internationally respected researchers and academics include: Robert Emery, PhD., Professor of Psychology in the Department of Psychology and Director of the Center for Children, Families and the Law, University of Virginia: “Despite influencing many custody proceedings, Gardner’s ideas fail to meet even minimal scientific standards.” Source: Robert E. Emery, “Parental Alienation Syndrome: Proponents Bear the Burden of Proof” (2005) 43:1 Family Court Review 8; Robert Geffner, Clinical Research Professor and adjunct faculty member for the National Judicial College, as well as author of numerous books on domestic violence and child abuse has commented: “While some parents resort to such behavior, parent alienation syndrome is not a valid diagnosis and shouldn’t be admitted into child custody cases.” Robert Geffner, “Editor’s note about the special section” (2016) 13:2-3 Journal of Child Custody 111; Walter DeKeseredy, Molly Dragiewicz & Martin Schwartz, “A Word of Caution about parental alienation” in Walter DeKeseredy, Molly Dragiewicz & Martin Schwartz, Abusive Endings: Separation and Divorce Violence Against Women (Oakland: University of California Press, 2017) 136; R. Freeman & G. Freeman, Managing Contact Difficulties: A Child Centered Approach (Ottawa: Department of Justice Canada, 2003); S.J. Dallam, “Parental Alienation Syndrome: Is it scientific?” in E. St. Charles & L. Crook, eds., Expose: The failure of family courts to protect children from abuse in custody disputes (Los Gatos, CA: Our Children Charitable Foundation, 1999) (online); J.S. Meier, Parental Alienation Syndrome and Parental Alienation: A Research Review Research Forum (National Online Resource Centre on Violence Against Women, 2009); Joan Meier & Sean Dickson, “Mapping Gender: Shedding Empirical Light on Family Courts’ Treatment of Cases Involving Abuse and Alienation” (2017) 35:2 Law & Inequality 310; P. Van Horn & B. M Groves, “Children Exposed to Domestic Violence: Making Trauma Informed Custody and Visitation Decisions” (2006) 57:11 Juvenile and Family Court Review 51; Smith, supra note 3; Dalton et al., supra note 3; Bruch, supra note 3.6 For example, Richard A. Warshak, formerly associated with Family Bridges workshops in the United States; Amy J. Baker; Stanley Clawar, clinical sociologist, and owner of Walden Counselling & Therapy; Barbara Jo Fidler of Families Moving Forward.7 Sources cited supra note 3; Rebecca Thomas & James Richardson, “Parental Alienation Syndrome: 30 years On and Still Junk Science” (2015) 54 :3 Judge’s Journal (online); Daniel Krauss, Psychological Expertise in Court (city: Routledge, 2016); Isabelle Côté & Simon Lapierre, L’Aliénation Parentale Stratégie D’Occultation De La Violence Conjugale? (Ottawa: FemAnVi, 2019) Online: http://fede.qc.ca/sites/default/files/upload/documents/publications/ rapport_ap.pdf.
📷 📷child harm that are known to have a negative impact on children's relationships with parents and that have been documented repeatedly in research on child well-being for decades, i.e., parental conflict, intimate partner and family violence, child abuse, weak parent-child attachment, parental neglect, parental substance misuse and/or negative or hostile parenting;10 2) Gender bias in the application and effects of parental alienation claims;11 3) Deflection of attention from scrutiny of parenting practices and parent-child relationships in favor of projecting blame onto primary-care parents when children have poor relationships withthe other parent;128 Michael Saini et al., “Empirical Studies of Alienation” in Leslie Drozd et al., eds, Parenting Plan Evaluations: Applied Research for Family Court (New York: Oxford University Press, 2012) 399. Sociologist Stanley Clawar’s research is commonly cited by parental alienation advocates in support of assertions of the scientific research validity of parental alienation theory. The claim is made that Clawar and Rivlin’s empirical research documenting parental alienation and its associated child and parental behaviors is based on analysis of more than 700 (now 1000) cases. However, scrutiny of the empirical basis for the claims made by Clawar and Rivlin, supra note 4, “Appendix: Research Techniques and Sample Characteristics,” reveals that the Clawar and Rivlin analysis is derived from client files seen in their professional practice and subsequently analyzed by the authors. In the absence of research samples and research controls, we have no way of knowing the degree to which the authors’ conclusions can be extended beyond clinical samples to the general public, and we have no way of knowing the extent to which the authors considered and controlled for scientifically verified and professionally accepted adversities that affect children’s relationships with their parents. Clawar and Rivlin’s conclusions should be considered therapeutic theory drawn from clinical practice rather than scientific research.9 Jean Mercer, “Are intensive parental alienation treatments effective and safe for children and adolescents?” (2019) Journal of Child Custody https://doi.org/10.1080/15379418.2018.1557578. Although Dr. Amy Baker has testified in Canadian courts, for example, Hukerby v. Paquet  S.J. no 791, that her research is longitudinal, and other parental alienation advocates have advised courts that Dr. Baker’s conclusions are based on “long-term’ research.” In fact, her research was actually merely qualitative and retrospective. For particulars, see: Amy J. L. Baker, “The Long- Term Effects of Parental Alienation on Adult Children: A Qualitative Research Study” (2006) 33:4 American Journal of Family Therapy 289; Amy J. L. Baker, Adult Children of parental alienation syndrome: Breaking the ties that bind (New York: W.W. Norton Professional, 2007). In contrast, a longitudinal study is a research design that involves repetitive observations and assessments of the same variables over a period of time. For example, a longitudinal study of parental alienation would start with use of a validated instrument (of which there are none) to identify a sample of children who were alienated from a parent. It would then follow and reassess the children at various points throughout their lives in comparison with children who were not alienated from a parent. Well-designed longitudinal studies implement experimental controls in order to distinguish the effects of parental alienation from the effects of other adversities on children. Dr. Baker’s parental alienation research is retrospective, based on adult memory of childhood experiences and lacking in research controls. Indeed a small longitudinal study of cases in which children resisted parental contact reveals that negative outcomes for children, when they exist in these cases, can be explained by serious deficits on the part of parents the children reject: Janet Johnson & Judith Goldman, “Outcomes of Family Counselling Interventions With Children Who Resist Visitation: An addendum to Friedlander and Walters” (2010) 48:1 Family Court Review 112.10 Without research controls it is impossible to distinguish the influence of parental alienation from the influence of other factors. Scott Huff, “Expanding the Relationship between Parental Alienating Behaviors and Children’s Contact Refusal Following Divorce: Testing Additional Factors and Long-Term Outcomes” (Doctoral Dissertation, University of Connecticut, 2015).11 Meier & Dickson, supra note 5; Madelyn Milchman, “Misogyny in New York Custody Decisions with Parental Alienation and Child Sexual Abuse Allegation” (2017) 14 J. Child Custody 234; Simon Lapierre & Isabel Côté, “Abused Women and the Threat of Parental Alienation: Shelter Workers’ Perspectives” (2016) 65 Child & Youth Servs. Rev. 120; Sian Balmer et al., “Parental alienation: Targeted parent perspective” (2018) 70 Australian Journal of Psychology 91. Note that the Balmer study differs from the other studies in that the focus was on the more particularly severe impact on mothers when fathers undermined mothers’ relationships with children. Fathers often allege PA as a tactic in response to mothers’ claims domestic violence or abuse or in order to present mothers’ resistance to equal time parenting and equal shared parenting responsibility in a negative light: S Berns, “Parents behaving badly: Parental alienation syndrome in the family court: magic bullet or poisoned chalice?” (2001) 15:3 Australian Journal of Family Law 191; R Kaspiew, “Empirical Insights into Parental Attitudes and Children’s Interests in Family Court Litigation”
📷 📷 📷 📷 📷 📷 📷 📷📷 4) Deflection of attention from scrutiny of child risk and safety factors, particularly in family violence cases;13 5) Imposition of equal time, joint custody, and co-parenting assumptions by parental alienation advocates;14 6) Deflection of attention away from thorough analysis of the best interests of children criteria in the legal system;15 7) The silencing of women and children such that evidence of family violence and of negative parenting is not presented to courts16 8) The discounting of the perspectives of children and the non-protection of children from parental abuse, contrary to the internationally recognized rights of children set out in the United Nations Convention on the Rights of the Child);17 and 9) The inappropriate assignment of parental blame for behaviors of adolescents that are normal and consistent with the needs of youth at an adolescent stage of development.18Family violence and child welfare associations in many parts of the world have become increasingly concerned about misuse of parental alienation concepts to the detriment of women and children.Child resistance to contact and child harm are better explained by factors other than those proposed by parental alienation theoryDiscussion: Scrutiny of emerging arm’s length research utilizing research controls and credible research methods reveals that the premises of parental alienation enthusiasts do not stand up to research scrutiny. Instead, it becomes clear that factors long identified in child-welfare and development research, such as lack of parental warmth, exposure to parental or family violence and/or parental(20017) 29:1 Sydney Law Review 131.12 Milchman, ibid; Nancy Erickson, “Fighting False Allegations of Parental Alienation Raised as Defenses to ValidClaims of Abuse” (2013) 6:1 Family & Intimate Partner Violence Quarterly 35; Meier & Dickson, supra note 5; Neilson (2018), supra note 3; Smith, supra note 3; Lois Shereen Winstock, “Safe Havens or Dangerous Waters? A Phenomenological Study of Abused Women’s Experiences in the Family Courts of Ontario” (PhD dissertation in Law, York University, 2014).13 Erickson, ibid.; Daniel Saunders & Kathleen Faller, “The Need to Carefully Screen For Family Violence When Parental Alienation is Claimed” (2016) 46:6 Michigan Family Law Journal 7; Rita Berg, “Parental Alienation Analysis, Domestic Violence, and Gender Bias in Minnesota Courts” (2011) 29:1 Law & Inequality 5; Joan Meier, “Domestic Violence, Child Custody, and Child Protection: Understanding Judicial Resistance and Imagining Solutions” (2003) 11 Am. U. J. Gender Soc. Pol’y & L. 657; Meier & Dickson, supra note 5; Neilson (2018), supra note 3.14 Bruch, supra note 3; Joyanna Silberg et al., Crisis in Family Court: Lessons From Turned Around Cases (2013); Neilson (2018), supra note 3; Smith, supra note 3; Milchman, supra note 11; Meier & Dickson, supra note 5; Erickson, supra note 12; Suzanne Zaccour, “Parental Alienation in Quebec Custody Litigation” (2018) 59 Cahiers de droit 1072; Winstock, supra note 12; Zoe Rathus, “Mapping the Use of Social Science in Australian Courts: The example of family law children’s cases” (2016) 25:3 Griffith Law Review 352.15 Bruch, supra note 3; Neilson (2018), supra note 3; Smith, supra note 3; Meier & Dickson, supra note 5; Erickson, supra note 12; Pamela Cross, Alienating children or protecting them? (online at Pamela Cross.ca, 2018)).16 Linda Neilson et al., “Spousal Abuse, Children and the Legal System” (Fredericton: Muriel McQueen Fergusson Centre for Family Violence Research, 2001); Leanne Francia et al., “Addressing family violence post separation – mothers and fathers’ experiences from Australia” (2019) Journal of Child Custody https://doi.org/10.1080/15379418.2019.1583151.17 Honourable Donna J. Martinson & Caterina E. Tempesta, “Young People as Humans in Family Court Processes: A Child Rights Approach to Legal Representation” (2018) 31 Can. J. Fam. L. 151; Special Issue, “A Renewed Call to Address Women’s and Children’s Human Rights” (2014) 18:6 International Journal of Human Rights; Neilson (2018), supra note 3.18 Joan Kelly & Janet Johnston, “The Alienated Child: A Reformulation of Parental Alienation Syndrome” (2001) 39:3 Family Court Review 249; Neilson (2018), supra note 3.
📷 📷conflict, offer far better explanations for child resistance to contact than does parental alienation theory. In fact, these long-documented factors19 often operate in opposition to the premises of parental alienation theory. Dr. Scott Huff reports, in his 2015 doctoral dissertation, University of Connecticut:These findings are notable in that alienating behaviors were not predictors of outcomes in any of the analyses, contrary to previous work on parental alienating behaviours (Baker & Verochio, 2012; Bena-Ami & Baker, 2012).20Similarly, Jenna Rowen, who studied the effects on children of parents denigrating the other parent, and Robert Emery have found that denigration patterns and the effects on children were consistent with conflict theory – we have long known that parental conflict is harmful to children – and not with parental alienation theory. Denigration problems were seldom one-sided or linear. Denigration alone seldom resulted in the successful manipulation of a child against the other parent. Instead, denigration usually had the opposite effect of impairing the child’s relationship with the parent engaging in denigration.21In other words, the child relevant factors verified by significant bodies of research – family violence, parental conflict, absence of parent-child warmth, weak parent-child attachment, parental neglect, negative parenting – that are known to be associated with children’s resistance to parental contact are both different from and more complex than the alienation theory’s primary focus on blaming the preferred parent. Yet, as Jean Mercer has documented, parental alienation advocates ask us to ignore these plausible explanations in favor of adopting a simplistic, one dimensional, speculative view of parent-child relationships that ignores most of the scientifically verified parent-child relationship factors.22Parental alienation remedies are harming some children.Discussion: Parental alienation experts typically recommend that children be removed from preferred parents without any contact while children undergo “reunification therapy” for a substantial period of time to restore or build positive relationships with the parent the children rejected. Stephanie Dallam and Joyanna Silberg, of the Leadership Council on Child Abuse and Interpersonal Violence, report that the treatments recommended by parental alienation therapists are likely to cause children foreseeable and lasting psychological harm, particularly when children have already been traumatized by negative family experiences.23 Indeed, removing children from preferred primary-care parents is contrary to research on child resilience, recovery from trauma and accepted child development principles.24 While reunification programs may help children in some cases, for example when the parent who engaged in domestic violence has undermined the child’s relationship with the abused parent in order to retain coercive control over the family (a common phenomenon in domestic violence cases), we actually19 See, for example, L. Neilson, “Spousal Abuse, Children and the Courts: The Case for Social Rather than Legal Change” (1997) 12:1 Canadian Journal of Law and Society 101, in connection with the large number of consistent research studies documenting the negative impact of parental conflict on children.20 Huff, supra note 10.21 Jenna Rowen, “Examining Parental Denigration in Family Law Systems and its Association with Parent-childCloseness, Interparental Conflict, and Psychological Well-Being” (PhD Dissertation, University of Virginia, 2014);Emery, supra note 5.22 Mercer, supra note 9.23 Stephanie Dallam & Joyanna Silberg, “Recommended treatments for ‘parental alienation syndrome’ (PAS) may causechildren foreseeable and lasting psychological harm” (2016) 2-3 Journal of Child Custody 134.24 Center on the Developing Child, Harvard University, Resilience.
📷 📷 📷 📷 📷📷 📷 📷 📷 📷📷 📷know very little about the short or long-term effects on children, positive or negative, of reunification therapy. While positive claims have been advanced by those who are, or have been, associated with and financially benefited from the delivery of such programs,25 arm’s length, controlled experimental research is lacking.26We do not know much, if anything, about the impact of the removal of children from their preferred parent and engagement in “reunification” attempts; about the effects on children’s relationships with preferred parents, siblings and other family members; or about the impact on children’s overall health and well-being. Moreover, anecdotal news reports are emerging now from children old enough to comment on experiences in reunification programs without risk of being censored or disciplined by the legal system. These children report having been forced to attend these programs; being threatened and intimidated; loss of contact with preferred parents, siblings and family members; being exposed to pro- father, anti-mother rhetoric; not being listened to and having their views treated respectfully; and not being protected from parental abuse.27 Although much of the emerging evidence from children is anecdotal and case specific, such that it is possible that other children had favorable experiences, the emerging experiences of children suggest the need for caution. We need to know a great deal more about the circumstances in which children are helped or harmed by such programs. Until the positive effects of reunification therapy are confirmed by arm’s length, longitudinal research,28 the current evidence does not support court-imposed reunification programs.29Judges are not mental health experts. Inclusion of parental alienation in the diagnostic manual will result in courts not appreciating the need to assess the scientific validity of the concept when assessing admissibility and will lead to simplified and erroneous assumptions about the appropriateness of proposed remedies. Children will be harmed.The parental alienation concept has a negative effect on evidence and on legal responsibilities to assess children’s best interests and safety:Discussion: Inclusion in the diagnostic manual would be detrimental to best interests of the child determinations in the legal system and contrary to the educational efforts of judicial educators. The National Council of Juvenile and Family Court Judges in the United States warns against application of parental alienation theory in family law cases, particularly in cases involving allegations of family violence:3025 For example: Richard Warshak, “Reclaiming Parent-Child Relationships; Outcomes of Family Bridges with Alienated Children” (2018) Journal of Divorce and Remarriage https://doi.org/10.1080/10502556.2018.1529505.26 Mercer,supranote9.27 Mercer, supra note 9; Vicky Nguyen, et al, No Oversight for Programs Advertising They Reconnect Children withAlienated Parents (NBC Bay Area, Investigative Unit, 2018); Cara Tabachnick, “They were taken from their mom to rebond with their dad. It didn’t go well” Washington Post (11 May 2017); Pei-Sze Cheng, “I-Team: NJ Brother, Sister Rip ‘Alienating’ Divorce Program That Tore Them From Father For Years” New York TV (26 December 2018) https:// www.nbcnewyork.com/news/local/Divorce-Camp-New-Jersey-Investigation-503506061.html; Trey Bundy et al., “Bitter Custody” Revealnews.org (9 March 2019).28 Nguyen, ibid.29 Doughty et al. (2018a), supra note 3; Doughty et al. (2018b), supra note 3; Dallam & Silberg, supra note 23.30 National Council of Juvenile and Family Court Judges, A Judicial Guide to Child Safety in Custody Cases (2008);Barry Goldstein, “Why Family Courts Cannot Protect Children: ACE vs. PAS” (Denver: National Organization for Men Against Sexism, no date).
📷The discredited ‘diagnosis’ of “PAS” (or allegation of “parental alienation”), quite apart from its scientific invalidity, inappropriately asks the court to assume that the children’s behaviors and attitudes toward the parent who claims to be alienated have no grounding in reality. It also diverts attention away from the behaviors of the [disliked] parent, who may have directly influenced the children’s responses by acting in violent, disrespectful, intimidating, humiliating and/or discrediting ways towards the children themselves, or the children’s other parent.Analysis of “expert” parental alienation testimony in family law cases in Canada reveals that parental alienation “experts” testifying in Canadian courts are advising courts to ignore: the views of children; evidence of child well-being while in the care of the child’s preferred parent; evidence of negative parenting on the part of the alienation claimant; and evidence of children’s therapists in favor of adopting parental alienation theory and denying children contact with the parent they prefer in order to restore or create a relationship with the parent the children reject.31 Case law in Canada and the United States is documenting children being forcefully removed by police from the homes of primary-care parents children prefer, sometimes repeatedly, and placed with parents the children fear or reject.32 In a number of Canadian cases children have applied to be removed from parental authority entirely in order to escape parenting arrangements imposed on them by courts.33Similarly, American researcher Joan Meier and colleagues, reporting on a major study of parental alienation cases in the United States, and Suzanne Zaccour in Canada, have found that alienation claims are resulting in evidence of paternal abuse of women and children being ignored by courts, in the removal of children from parents (primarily mothers) who seek to protect them, and in children’s placement with abusive parents, even in cases where judges made positive findings of family violence and abuse.34 Indeed Meier and colleagues report that women who present evidence of child abuse are more apt to lose custody of their children than women who merely report intimate partner violence, and that cross-claims of parental alienation virtually double the rate of mothers’ custody losses.35 Joyanna Silberg et al., also reporting from the United States, examined legal cases in which family violence and child abuse claims were initially considered false (as a result of misplaced judicial scepticism36 and/or the impact of alienation claims) but ultimately resulted in findings of abuse and in the return of children to protective parents. The authors report, on the basis of scrutiny of the case law, that when courts placed children with abusive parents the abuse continued, and a third of these children attempted suicide. When courts subsequently made positive findings of abuse and returned children to the custody of protective parents, the children had spent an average of three years in abusive parents’ care.37 Experts in many countries are now documenting concerns about the well-being of children and children’s relationships with abused parents in cases when alienation theory is applied by courts.31 Neilson (2018), supra note 3.32 Meier & Dickson, supra note 5; Neilson (2018) supra note 3; Silberg et al., supra note 14.33 Neilson (2018), supra note 3.34 Meier & Dickson, supra note 5; Zaccour, supra note 14.35 Ibid.36 In connection with judicial and legal scepticism and the reasons for such scepticism throughout the legal system, referto Deborah Epstein & Lisa Goodman, “Discounting Credibility: Doubting the Testimony and Dismissing theExperiences of Domestic Violence Survivors and Other Women” (2018) 167 U. Penn. L. Rev. forthcoming.37 Silberg et al., supra note 14.
📷 📷 📷 📷📷 📷📷 📷 📷 📷 📷 📷 📷📷 📷 📷 📷📷 📷 📷 📷📷 📷 📷📷 📷 📷 📷Child research clearly documents the negative impact of family violence on children and on post separation parenting and the need to listen carefully and respectfully to the views of childrenDiscussion: We know, from a consistent body of research over decades, that family violence against children's caregivers in children's homes causes direct, scientifically documented child stress and harm. The violence need not be witnessed directly in order to cause harm. Some of these children will experience long term fear responses and emotional --even developmental-- harm.38 Documentation of direct harm to children from violence directed against adult caregivers is consistent across research methods (qualitative and quantitative) and even across disciplines (social science, medicine, psychiatry, child development, neurobiology).39 The research also tells us that perpetrating abuse against mothers commonly occurs together with abuse and violence directed at children40 and that child disclosure rates are low.41 The post separation parenting patterns research from many countries also tells us that negative perpetrator parenting – such as demeaning domination, monitoring and surveillance, isolation, excessive physical discipline, and coercive control – continues and often gets worse following parental separation, once the abused parent is no longer able to shield or buffer the children – that is, after the adults separate,42 if the perpetrator has unsupervised access to the children.Nonetheless, those family lawyers, mediators, evaluators and judges who do not understand that parental intimate partner violence is directly associated with child harm and child abuse43 are silencing38 National Scientific Council on the Developing Child at Harvard University, Persistent Fear and Anxiety Can Affect Young Children’s Learning and Development (2010) and educational materials on toxic stress. For discussion of pertinent research, see Linda C Neilson, Chapter 6 “Children: Impact of Domestic Violence & Evidence of Children” in Responding to Domestic Violence in Family Law, Civil Protection and Child Protection Cases (Ottawa: CanLII, 2017); Sibylle Artz et al., “A Comprehensive Review of the Literature on the Impact of Exposure to Intimate Partner Violence for Children and Youth” (2014) 5:4 International Journal of Child, Youth and Family Studies 493.39 Refer, for example, to the lengthy list of references on this issue in “Supplementary Reference Bibliography: Effects of Domestic Violence on Children”, Responding to Domestic Violence in Family Law, Civil Protection and Child Protection Cases (Ottawa: CanLII, 2017).40 Child Welfare Information Gateway & U.S. Department of Health & Human Services, Domestic/Intimate Partner Violence (reference materials on the connections between domestic violence and abuse directed at children); Australian Government materials on Domestic violence and child abuse and neglect; Jeffrey Edleson, “The Overlap Between Child Maltreatment and Woman Battering” (1999) 5:2 Violence Against Women 134.41 Jane Callaghan et al., “The Management of Disclosure in Children’s Accounts of Domestic Violence: Practices of Telling and Not Telling” (2017) 26:12 J Child Fam Stud. 3370; Statistics Canada, Family violence in Canada: A statistical profile, 2015. (Ottawa: Stats Canada, 2017) Catalogue no. 85-002-X, see Child disclosure.42 L. Bancroft, J. Silverman & D. Ritchie, The Batterer as Parent: Addressing the Impact of Domestic Violence on Families (2nd ed) (Los Angeles: Sage, 2012); Linda Neilson et al. (2001), supra note 16; Australia’s National Research Organization for Women’s Safety (hereafter ANROWS), Domestic and family violence and parenting: Mixed Methods insights into impact and support needs: Key findings and future directions (Sydney: ANROWS, 2017; Dale Bagshaw et al., The effect of family violence on post-separation parenting arrangements in Family Matters 86 (Canberra: Australian Government, 2011); ANROWS, The impacts of domestic and family violence on children (summarizing major Australian research studies) (Sydney: ANROWS, 2017).43 Researchers are reporting that many custody evaluators do not have sufficient understanding of domestic violence to assess child best interests in a domestic violence context: Daniel Saunders et al., Child Custody Evaluators' Beliefs About Domestic Abuse Allegations: Their Relationship to Evaluator Demographics, Background, Domestic Violence Knowledge and Custody-Visitation Recommendations (Rockville, MD: National Criminal Justice Research Service, 2012); Daniel Saunders, State Laws Related to Family Judge’s and Custody Evaluators’ Recommendations in Cases of Intimate Partner Violence: Final Summary Overview (Rockville, MD: National Criminal Justice Research Service, 2017); Michael Davis et al., Custody Evaluations When There are Allegations of Domestic Violence: Practices, Beliefs, and Recommendations of Professional Evaluators (Rockville, MD: National Criminal Justice Research Service, 2011); Jason Hans et al., “The Effects of Domestic Violence Allegations on Custody Evaluators’ Recommendations” (2014) 28:6 Journal of Family Psychology 957; Jennifer Hardesty et al., Divorcing Mothers’ Demeanor in Custody
📷 📷 📷 📷📷 📷📷 📷 📷 📷 📷📷 📷 📷📷 📷 📷 📷📷 📷 📷 📷📷 📷 📷 📷📷 📷 📷📷 📷📷 📷 📷 📷 📷 📷women and are failing to investigate and consider women and children’s concerns about parenting and safety in favor of punishing parents – primarily mothers -- (and children) when children resist contact with the other parent.44 Children are being forcibly removed from the parents they prefer and are being forced into homes and parenting relationships they resist (on the basis that the mother did not sufficiently strongly insist on the child’s relationship with the other parent).45 Children are running away.46 Some attempt suicide; others are killed.47 Researchers are currently documenting the contributing role of family courts in child deaths as a result of family court orders mandating children into unsupervised contact with abusive fathers.48When we turn to children for guidance, we find that children are telling researchers to ask family courts and those associated with family courts to listen and consider more respectfully children’s views on contact with perpetrators of family violence (some children desire contact, others do not) and to pay more attention to children’s concerns about their own and their siblings’ safety. Children are also asking researchers to ask family courts to hold perpetrators of domestic and family violence accountable for harm done to the family and to ensure that perpetrators accept responsibility, apologize and make amends prior to insisting on parenting rights.49Evaluations (Reno, NV: National Council of Juvenile and Family Court Judges, undated); Samantha Jeffries et al., “Good Evidence, Safe Outcomes in Parenting Matters Involving Domestic Violence? Understanding Family Report Writing Practice from the Perspective of Professional Working in the Family Law System” (2016) 39:4 UNSW Law Journal 1355. See also the problems identified in Linda C Neilson et al. (2001), supra note 16 and Neilson (2018), supra note 3; Samantha Jeffries, “In the Best Interests of the Abuser: Coercive Control, Child Custody Proceedings and the “Expert” Assessments that Guide Judicial Determinations” (2016) 5:14 Laws 1; Francia et al., supra note 16; Nancy S Erickson, “Use of the MMPI-2 in Child Custody Evaluations Involving Battered Women: What Does Psychological Research Tell Us?” (2005) 39:1 Family Law Quarterly 87; Nancy S Erickson & Joan Zorza, “Evaluating the Handling of Domestic Violence Cases by Custody Evaluators” (2005) 10:4 Domestic Violence Report 49.44 Silberg et al, supra note 14; Neilson (2018), supra note 3; Meier & Dickson supra note 5; Winstock, supra note 12; Katia Gagnon, “Violence conjugale. Quand on punit la victime” La Presse (9 March 2019), citing parental alienation research conducted by University of Ottawa researcher, Simon Lapierre: http://plus.lapresse.ca/screens/dea4748e-69d8- 4aed-8326-c11bf9b58c25__7C___0.html; Zoe Rathus et al., “‘It’s Like Standing on a Beach, Holding Your Children’s Hands, and Having a Tsunami Come Towards You’: Intimate Partner Violence and Expert Assessments in Australian Family Law” (2019) Victims and Offenders https://doi.org/10.1080/15564886.2019.1580646.45 Ibid.46 Neilson (2018) supra note 3; Silberg, supra note 14.47 Silberg et al, supra note 14 Francia et al., supra note 16; Neilson (2018), supra note 3; Lori Chambers et al., PaternalFilicide & Coercive Control” (2018) 51:3 UBC Law Review 671; Winstock, supra note 12; Mary Ellen Turpel-Lafond, Honouring Christian Lee — No Private Matter: Protection Children Living with Domestic Violence (Victoria: Legislative Assembly British Columbia, 2009); Alberta Government, Family Violence Death Review Committee Case Review No.3 (2018); Saskatchewan Domestic Violence Death Review Report (Edmonton: Ministry of Justice, 2018); David Olszowy et al., Children and Domestic Homicide: Understanding the Risks (London, ON: Canadian Domestic Homicide Prevention Initiative, 2017); Myrna Dawson, “Canadian Trends in Filicide by Gender of the Accused, 1961- 2011” (2015) 47 Child Abuse & Neglect 162; Susan Boyd & Gillian Calder, “Connecting the dots in family-violence cases” [Victoria] Times Colonist (3 January 2018); Department of Justice, Case Study – Different systems may have information relevant to risk assessment in Chapter 2 – Risk assessment Making the Links in Family Violence Cases: Collaboration among the Family, Child Protection and Criminal Justice Systems (Ottawa: Department of Justice, 2013); United States Center for Judicial Excellence, U.S. Divorce Child Murder Data and 58 Children Murdered By A Parent Who Could Have Been Saved -- Filicide in U.S. Family Courts: A Snapshot (2017); Lauren L. Sabatino,Looking at Family Court-Involved Domestic Violence and Child Abuse Fatality Cases Through a Lens of Prevention (Miami: Institute for Court Management, 2009); Women’s Aid, Nineteen Child Homicides (Bristol: Women’s Aid, 2016).48 Chambers et al., ibid.; Turpel-Lafond, ibid.; Alberta Government (2018) ibid.; Saskatchewan (2018) ibid.; United States Center for Judicial Excellence, ibid; Sabatino, ibid.49 Katie Lamb, Cathy Humphries & Kelsey Hegarty, “Your behavior has consequences: Children and young people’s perspectives on reparation with their fathers after domestic violence” (2018) 88 Children and Youth Services Review 164; Rachel Carson et al., Children and young people in separated families: Family Law system experiences and needs (Australian Government, Institute of Family Studies, 2018); Backbone Collective, Seen and not Heard: Children in the
📷 📷📷 📷📷 📷📷 📷 📷 📷📷 📷 📷 📷 📷 📷 📷 📷 📷 📷 📷 📷 📷📷 📷 📷 📷 📷📷 📷 📷📷In Conclusion:There is far more support for identifying intimate and family violence as a parent-child relationship problem than for identifying "parental alienation" as a parent-child relationship problem.Indeed, the inclusion of "parental alienation" anywhere in the ICD-11 diagnostic manual is likely to strengthen existing destructive trends in family courts that are causing children and their primary caregivers harm. In addition, empirically validated concerns about the concept's lack of reliability couldcall into question the scientific credibility of the World Health Organization as well as the reliability of the International Classification of Diseases.Additional references:Miguel Clemente & Delores Padilla-Racero “When courts accept what science rejects: Custody issues concerning the alleged “Parental alienation syndrome” (2016) 13:2-3 Journal of Child Custody 126- 133.Jodi Death, Claire Ferguson, and Kylie Burgess “Parental alienation, coaching and the best interests of the child: Allegations of child sexual abuse in the Family Court of Australia” (2019) 94 Child Abuse & Neglect 101045.Julie Doughty et al. (2019) Alienating behavior in post-separation parenting disputes CASCADE Research Briefing.Elizabeth Liu and Barry Goldstein Representing the Domestic Violence Survivor (Kingston, NJ: Civil Research Institute, 2013).Joan Meier, Sasha Drobnick, Aryeh Kaufman, Karen Wiswall (2019) Court of Appeals, State of New York, Brief of Domestic Violence Legal Empowerment and Appeals Project, American Professional Society on the Abuse of Children et al.Joan Meier (2019) Child Custody Outcomes in Cases Involving Parental Alienation and Abuse Allegations https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3448062United Nations Special Rapporteur on Violence Against Women: Final Statement VAW and custody Platform of Mechanisms June 2019. Refer to Expert Committee concerns about the inclusion of ‘parental alienation’ as an index term in the new WHO ICD-11 as well as the Committee of Experts recommendation to explicitly prohibit use of alienation concepts during investigations to determine the existence of violence at page 3.Working group on complex divorces – multidisciplinary collaboration (CSMS) It won’t stop until you protect the victims at 32-45 and 80-81.New Zealand Family Court. Part One – Force (2017) and Seen and not Heard: Children in the New Zealand Family Court. Part Two-- Lawyer for Child (2018); Gillian Macdonald, “Hearing children’s voices? Including children’s perspectives on domestic violence in welfare reports prepared for the English courts in private family law proceedings” (2017) 65 Child Abuse & Neglect 1; Jane Fortin, Joan Hunt & Lesley Scanlan, Taking a longer view of contact: The perspectives of young adults who experienced parental separation in their youth (Sussex: University of Sussex, 2012); Audrey Mullender et al., Children’s Perspectives on Domestic Violence (London: Sage, 2002); R Carsen et al., Children and young people in separated families: Family law system experiences and needs (Melbourne: Australian Institute of Family Studies, 2018).
List of experts and institutions from endorsing this memo and seeking removal of all references to parental alienation from ICD-11.The following 352 experts and organizations from 36 countries and 764 individuals from Italy (as of July 2, 2019) endorse this memo and seek removal of references to “parental alienation” and related concepts from the index of ICD-11, International Classification of Diseases. ALBANIA Institutions: 1. Albanian Women’s Empowerment Network 2. Gender Alliance for Development Center 3. Women to Women (Gruaja tek Gruaja) ARMENIA: Institution: 4. Women’s Support Center AUSTRALIA Experts: 5. Dr. Renata Alexander, Senior Lecturer, Faculty of Law, Monash University, Melbourne 6. Moo Baulch, CEO, Domestic Violence NSW, Sydney, Australia 7. Dr Karen Crawley, Senior Lecturer, Griffith Law School, Brisbane, Australia 8. Professor Heather Douglas, Law School, the University of Queensland, Australia 9. Dr Molly Dragiewicz, Associate Professor, School of Justice, Faculty of law, Queensland University of Technology 10. Professor Patricia Easteal, AM, PhD, Consultant, Legal Lightbulbs, Australia 11. Belinda Fehlberg, Professor of Law, Melbourne Law School 12. Dr Michelle Fernando, Senior Lecturer, School of Law. University of South Australia, Adelaide, South Australia, Australia 13. Hayley Grainger, Assistant Director & Solicitor, North Queensland Women’s Legal Service, Australia 14. Dr Samantha Jeffries, Senior Lecturer, School of Criminology and Criminal Justice, Griffith University, Brisbane, Australia 15. Cathy Humphreys, Head of Department, Professor of Social Work, University of Melbourne 16. Janet Loughman, Principal Solicitor, Women’s Legal Service New South Wales 17. Diane Mangan, Chair, Australia National Foundation for the elimination of death related to domestic and family violence, Brisbane, Queensland
18. Professor Elena Marchetti, Griffith Law School, Brisbane, Australia 19. Elspeth McInnes AM, Associate Professor of Sociology in Education, Chair Human Research Ethics Committee, School of Education Magill, University of South Australia 20. Dr Helena Menih, PhD, Lecturer in Criminology, School of Humanities, Arts and Social Sciences, University of New England, Armidale NSW 2, Australia 21. Associate Professor Silke Meyer, Associate Professor in Criminology, Monash Gender and Family Violence Prevention Centre, Monash University. Melbourne, Australia 22. Associate Professor Carolyn Quadrio, Consultant Child & Family & Forensic Psychiatrist, School of Psychiatry University of New South Wales, Sydney, Australia 23. Zoe Rathus, Senior Lecturer, Griffith Law School, Brisbane, Australia 24. Joanne Stagg, Lecturer, Griffith Law School, Griffith University, Gold Coast, Australia. 25. Professor Julie Stubbs, UNSW LAW, Co-Director, Centre for Crime, Law & Justice, University of New South Wales, Sydney, Australia 26. Dr. Deborah Walsh, Lecturer and Family Violence Specialist, Faculty of Health and Behaioural Sciences, University of Queensland 27. Dr. Jane Wangmann, Senior Lecturer, Faculty od Law, University of Technology, Sydney 28. Karen Willis, OAM, Executive Officer, Rape and Domestic Services Australia, Drummoyne, Sydney, NSW 29. Professor Lisa Young, Associate Dean Research, Murdoch School of Law, Perth, Australia AUSTRIA: Institutions: 30. Domestic Violence Intervention Centre, Vienna 31. Osterreichischer Frauenring (Austrian Women’s Lobby) AZERBAJAN Institutions: 32. Clean World Aid to Women Soviet Union BELGIUM Institutions: 33. La Voix des Femmes BOSNIA AND HERZEGOVIA Institutions:
34. Foundation United Women Banja Luka BRAZIL Experts: 35. Juliana Ahn, Researcher, Representative of UNIDI 36. Patrícia Regina Alonso, lawyer, historian, writer, representative of Unigrejas, COPPAMM and ADVEC 37. Elizabethi Regina Alonso, lawyer, researcher, representative of CONIADI, CIPBAS and Casa Magnólia 38. Felicio Alonso - Lawyer, representative of Clamor pelo Brasil and Provida Profamilia, Brazil 39. Alessandra Andrade, Representative of Coletivo Voz Materna, Coalition of Mothers, RS, Brazil 40. Claudete Braghini, Representative of UNIDI 41. Luz Morena Cerroti, Representative of Coletivo Mães na Luta, Coalition of Mothers - Brazil 42. Rubia Abs Cruz, Advocate and member of CLADEM, Latin American And Caribbean Committee On The Defense Of Women's Rights – Brazil 43. Ana Maria Iencarelli, CEO of ONG Vozes de Anjos, Organization of advocacy and psychology support for children and women victims of Domestic Violence, Brazil 44. Patricia Massa, Public Prosecutor, Representative of UNIDI 45. Tanise de Siqueira, Psychologist (PUCRS ), Specialist in Clinical Psychology (Federal Council of Psychology - CFP), Psychotherapeutic Counseling Psychotherapeutic (Institute of Teaching and Research in Psychotherapy - IEPP), Vigere Psychotherapy, Porto Alegre/ RS, Brazil Institutions: 46. ONG Vozes de Anjos -Childhood and Maternity Protection 47. UNIDI - União Pela Defesa da Infância, Brazil BULGARIA Institutions 48. Alliance for Protection from Gender-based Violence 49. Bulgarian Gender Research Foundation 50. Mothers for Change Movement 51. Dinamika Centre Association 52. Pulse Foundation Individual Expert: 53. Gayla Petkova Doycheva CANADA Experts:
54. Dr. Ramona Alaggla, MSW, PhD, RSW, Professor, Factor-Inwentash Faculty of Social Work, University of Toronto 55. Dr. Dan T. Ashbourne, C. Psych, Executive Director & Psychologist, London Family Court Clinic, La Clinique Judiciaire Familiale de London, London, Ontario 56. Dr. Clive Baldwin, PhD, Professor of Social Work, Saint Thomas University, Fredericton 57. Carol Barkwell, Executive Director, Luke’s Place, Support and Resource Centre for Women and Children in Durham Region, Ontario 58. Suki Beavers, Project Director/directrice de projet, NAWL/ANFD, Ottawa, Ontario 59. Isabelle Boisclair, Professor, Université de Sherbrooke, Sherbrooke, Canada 60. Gabrielle Bouchard, President, Fédération des femmes du Québec 61. Mélissa Blais, professeure associée, Institut de recherches et d’études féministes, Université du Québec à Montréal, Canada 62. Susan Boyd, F.R.S.C., Professor Emerita, Peter A. Allard School of Law, University of British Columbia; 63. Andrea Breanne, McGill Law alumni, London, Ontario 64. Ksenia Burobina, PhD Candidate in Sociology, Université de Montréal, Canada 65. Dr. Sandra Byers, PhD, Professor, University of New Brunswick, Fredericton 66. Dr. Catherine Ann Cameron, PhD, Professor Emerita, University of New Brunswick and Honorary Emerita Professor of Psychology, University of British Columbia📷 67. Dr Isabelle Côté, Ph.D., Professeure adjointe, École de service social, Université Laurentienne, Bureau 68. Dr. Dianne Crocker, PhD, Associate Dean, Graduate Studies, Sociology and Criminology, Saint Mary’s University, Halifax 69. Pamela Cross, Family Lawyer and Legal Director, Luke’s Place, Ontario 70. Dr. Dominique Damant, Ph.D, Associate Professor, School of Social Work, Université de Montréal, Canada 71. Anick Desrosiers, doctoral student in social work, Université de Montréal, Montréal, Canada. 72. Dr. Marilyn Dupre, PhD, Director, School of Social Work, Saint Thomas University, Fredericton 73. Dr Francis Dupuis-Déri, Professor, Political Sciences, Université du Québec à Montréal, Canada 74. Jo-Anne Dusel, Executive Director, Provincial Association of Transitions Houses and Services of Saskatchewan (PATHS) 75. Dr Catherine Flynn, Ph.D., Professor, Department of Human and Social Sciences, Université du Québec à Chicoutimi, Canada
76. Michèle Frenette, PhD Student, University of Ottawa, Canada 77. Crystal Giesbrecht, Director of Research and Communications, Provincial Association of Transitions Houses and Services of Saskatchewan (PATHS) 78. Kasari Govender, Executive Director & Lawyer, West Coast LEAF, Vancouver, British Columbia 79. Kim Hawkins, Executive Director, Rise Women’s Legal Centre, Vancouver 80. Dr Catherine Holtmann, Ph.D., Director, Muriel McQueen Fergusson Centre for Family Violence Research, Associate Professor, Sociology, University of New Brunswick 81. Dr Margaret Jackson, PhD, Professor Emerita, Director of the FREDA Centre on Violence Against Women and Children 82. Rachel Jacques-Mignault, lawyer, Montreal, Canada 83. Dr Peter Jaffe, PhD, Psychologist & Professor, Academic Director, Center for Research and Education on Violence Against Women and Children, Western University, London ON, Canada 84. Dr Darlene Juschka, PhD, Associate Professor, Department of Gender, Religion, and Critical Studies and RESOLVE Alberta 85. Patrick Ladouceur, PhD Student, University of Ottawa, Canada. 86. Dr Michele Landsberg, LLD (Hons), Canadian journalist and author, member of the Order of Canada 87. Dr Simon Lapierre, Full Professor, School of Social Work, University of Ottawa 88. Dr Geneviève Lessard, Ph.D., Professeure titulaire, École de travail social et de criminologie, Université Laval (Québec, Canada), Directrice du Centre de recherche interdisciplinaire sur la violence familiale et la violence faite aux femmes 89. Dr Nicole Letourneau, RN, PhD, FCAHS, ACHF Chair in Parent-Infant Mental Health, Resolve Alberta Director & Principal Investigator, Child Studies Program, Calgary 90. Janet McGeachy, MSW, School of Social Work, Saint Thomas University, Fredericton 91. Dr. Nancy Nason-Clark, PhD, FRSC, Professor Emerita, Sociology, University of New Brunswick 92. Kendra Nixon, Associate Professor of Social Work, Director of RESOLVE Manitoba, University of Manitoba 93. Dr Linda C Neilson, LLB, Ph.D (Law, L.S.E.), Professor Emerita, University of New Brunswick Canada and Research Fellow of the Muriel McQueen Fergusson Centre for Family Violence 94. Kendra Nixon, Resolve, Manitoba, Provincial Association of Transitions Houses and Services of Saskatchewan (PATHS) 95. Danya O’Malley, Executive Director, PEI Family Violence Prevention Services, Charlottetown, PEI
96. Elizabeth Pickett, Canadian Feminist Network, Ottawa 97. Marie Josèphe Pigeon, general director of SEP – Service d’Entraide Passerelle, Montreal, Canada 98. Tracy Porteous, Executive Director, Ending Violence Association of British Columbia, Vancouver 99. Dr. Caren Poulin, Associate Dean, Faculty of Arts, Professor Psychology, Gender & Women Studies, University of New Brunswick 100. Sandrine Ricci, Doctoral candidate and lecturer, University of Québec in Montréal (UQAM) 101. Dr Elizabeth Sheehy, LLB, LLM, LLD (hons), Professor Emerita, University of Ottawa, Faculty of Law, F.R.S.C., Order of Ontario 102. Deborah Sinclair, MSW, RSW, PhD student, Therapist & Consultant, Lecturer, Factor- Inwentash, Faculty of Social Work, University of Toronto, Canada 103. Kharoll-Ann Souffrant, travailleuse sociale et candidate à la maîtrise en service social avec option en études féministes à l’université McGill 104. Dinaïg Stall, Professor, University of Québec in Montréal, Montreal, Canada 105. Dr. Leslie M. Tutty, PhD, Professor Emerita, Faculty of Social Work, University of Calgary It is important to note that there were Directors of the Canadian Family Violence Research Centres (including one past Director) who have endorsed this memo. Institutions: 106. Centre de femmes l’Autonomie en soie, Saint-Hyacinthe, Quebec 107. Fédération des femmes du Québec 108. Fédération des maisons d’hébergement pour femmes, Québec, Canada 109. Feminist Anti-Violence (FemAnVi) Research Collective, University of Ottawa, Canada 110. L’R des centres de femmes du Québec, Montréal, Canada 111. Luke’s Place, Support and Resource Centre for Women and Children in Durham Region, Ontario 112. Muriel McQueen Fergusson Centre for Family Violence Research, University of New Brunswick 113. National Association of Women and the Law (NAWL/ANFD), Ottawa, Ontario 114. Regroupement des maisons pour femmes victimes de violence conjugale, Montréal, Canada 115. Regroupement Naissance-Renaissance, Montreal, Quebec 116. Rise Women’s Legal Centre, Vancouver 117. West Coast LEAF, Vancouver, British Columbia. 118. Women’s Legal Education and Action Fund (LEAF FAEJ), Toronto, Canada
CROATIA Institutions: 119. Autonomous Womens House Zagreb 120. B.a.B.e. Be active, BE emancipated 121. Centre for Womens Studies 122. Centre for Women War Victims 123. Coordination of Womens Groups SEKA 124. Womens Network of Croatia CYPRUS Institution: 125. Association for the Prevention and Handling of Violence in the Family CZECH REPUBLIC Institutions: 126. proFem – Center for Victims of Domestic and Sexual Violence 127. ROSA – Center For Women EUROPE Institutions: 128. European Network Women Against Violence (WAVE) 129. Gwendoline Lefebvre, European Womens Lobby FRANCE Experts: 130. Isabelle Beck, Family Law Lawyer, Lyon, France 131. Dr. Maurice Berger, Ph D, child psychiatrist, chief of child psychiatric ward in a university hospital, Professor of child psychopathology in Lyon 2, director of training at the National School of Judges in Paris 132. Dr Catherine Bonnet, Consultant in child and adolescent psychiatry in France (1974-2003) in UK (2004-2007), Paris, France 133. Dr Anne-Marie Clement, President of the Fédération des Comités Alexis Danan pour la Protection de l’Enfance, Paris, France 134. Dr Annie Dudin, Pediatrician, Tours, France
135. Dr. Andreea Ernst-Vintila, Associate professor of psychology, Université Paris-Nanterre, Paris Research Center for Social Psychology EA 4386, France 136. Marie Françoise Caminada, psychologist, Gourdon, France 137. Dr Marie-Paule Grossetete, doctor in evolutionary biology, member of the board of director of Osez le féminisme!, Paris, France. 138. Marie-Christine Gryson, clinical psychologist, ex judicial expert (26 years), Lille, France 139. Caroline Guesnier, President of CIVIFF (Collectif International Vaincre les Injustices Faites aux Femmes) 140. Mélanie Jauner, responsible for Antenne Ouest et Haut de France CIVIFF (Collectif International Vaincre les Injustices Faites aux Femmes) 141. Dr Eugénie Izard, child psychiatrist, President of the REPPEA (Réseau de Professionnels pour la Protection des Enfants et des Adolescents), Toulouse, France 142. Dr Catherine Le Magueresse, lawyer, expert on violence against women, Paris France 143. Pierre-Guillaume Prigent, PhD Student, University of Western Britanny, France 144. Meryl Puget, clinical psychologist and psychologue clinicienne, member of the board of directors of Osez le féminisme!, Paris, France. 145. Alexandra Rhodes, Clinical Psychologist, Child Psychotherapist, Expert at the Courts - Toulouse Court of Appeal, Toulouse, France 146. Dr Hélène Romano, Dr in psychopathology, HDR PhD CPP Lyon Est III, Lyon, France 147. Dr Brigitte Mélot Slama, member of the Board of Directors of the REPPEA (Réseau de Professionnels pour la Protection des Enfants et des Adolescents), Bagnolet France 148. Lucie Sabau, member of the board of director of Osez le féminisme!, Paris, France 149. Gwénola Sueur, Réseau International des Mères en Lutte, France 150. Stéphanie Vecchiato, respsonsible Antenne Sud Ouest CIVFF (Collectif International Vaincre les Injustices Faites aux Femmes) 151. Galia Yehezkieli, Child psychiatrist, Charenton-le-Pont, France Institution: 152. Association REPPEA (Réseau de Professionnels pour la Protection des Enfants et des Adolescents, association of professionals network for child protection) GERMANY Experts: 153. Dr. Carol Hagemann-White, PhD, Professor, University of Osnabruck
ISRAEL Experts: 154. Gali Etzion, Attorney at Law, Director counselling & legislation department, Naamat Women’s Organization 155. Professor Daphna Hacker, Law Faculty and Head of Gender Studies Program, Tel Aviv University 156. Prof. Ruth Halperin-Kaddari, Professor at Bar-Ilan University Faculty of Law, Israel; Founding Head of the Rackman Center for the Advancement of Women at BIU; and former Vice-Chair of CEDAW 157. Dana Eisner-Lavi, Adv., Director of the Women’s Rights Clinic, College of Management School of Law Institution: 158. The Ruth and Emanuel Rackmen Center for the Advancement of Women, Bar-llan University, Faculty of Law IRELAND 159. Womens Aid Dublin ITALY Experts: 160. Avv. Simona D`Aquilio, Lawyer of the Italian Civil Forum, Member of the Rome COA. Maison Antigone Vice President 161. Mariachiara Feresin, PhD Student, University of Trieste 162. Avv. Michela Nacca, Lawyer of the Vatican City State and of the Apostolic Courts Superior, President of the Maison Antigone Association 163. Professor Patrizia Romito, PhD, Deputy Director for Equal Opportunities, Laboratory of Social and Community Psychology, University of Trieste, Italy Institution: 164. Maison Antigone, Albano, Laziale, Italy. As of July 2, 2019, 764 individuals had endorsed the Collective Memo to WHO seeking removal of all references to parental alienation and related concepts from the ICD-11 diagnostic manual on grounds of lack of scientific validity on the Maison Antigone web site. JAPAN Experts: 165. Dr. Yuki Senda, Professor Sociology, Musashi University
KOSOVO Institutions: 166. Womens Wellness Center LUXEMBOURG Institution: 167. Femmes en Detress asbl MALTA Institutions: 168. Network Forum Malta 169. SOAR ST Jeanne Antide Foundation 170. The Good Shepard Sisters – Dar Merhba B Foundation 171. Womens Rights Foundation NEW ZEALAND Experts: 172. Dr Peter Adams, Professor, Social & Community Health, University of Auckland 173. Dr Jackie Blue, former New Zealand Human Rights Commissioner (Women's Rights) 174. Jane Drumm, General Manager, Shine (Safer Homes in NZ Everyday) Auckland 175. Dr Vivienne Elizabeth, Associate Professor, Sociology, University of Auckland 176. Dr Nicola Gavey, Professor, Psychology, University of Auckland 177. Dr Deborah Hager, Lecturer, Health Promotion, School of Population Health, University of Auckland 178. Ruth Herbert, Co-Founder, The Backbone Collective 179. Dr Sue Jackson, Associate Professor, Psychology, Victoria University of Wellington 180. Dr Ang Jury, Chief Executive, National Collective of Women's Refuges, NZ 181. Dr Jade Le Grice, Lecturer, Psychology, University of Auckland 182. Deborah Mackenzie, Co-founder, The Backbone Collective, New Zealand 183. Dr Kathryn McPhillips, Clinical Psychologist, Executive Director, Auckland Sexual Abuse Help Foundation 184. Dr Mandy Morgan, Professor, Psychology, Massey University 185. Leonie Morris, Community Worker, Auckland Women's Centre, NZ 186. Nicola Paton, Family Violence Clearinghouse, University of Auckland, New Zealand
187. Dr Neville Robertson, Senior Lecturer, Psychology, Waikato University 188. Dr Michael Tarren-Sweeney, Professor of Child & Family Psychology, School of Health Sciences, University of Canterbury, New Zealand, editor of Developmental Child Welfare 189. Professor Julia Tolmie, Faculty of Law, The University of Auckland 190. Dr. Alison Towns, PhD, Dip Clin Psychology, Director Mt. Albert Psychological Services, Ltd., St. Lukes, Aukland. POLAND 191. Autonomia Foundation PORTUGAL 192. Association of Women Against Violence, AMCV 193. Contra femincidio – associacao de familias amigas de vitimas de fernicidio REPUBLIC OF NORTH MACEDONIA 194. National network to end violence against women and domesta violence ROMANIA 195. Association for Liberty and Equality of Gender A.L.E.G. SERBIA 196. Association of Women Sandglass 197. Autonmous Womens Center 198. Counseling For Lesbians 199. Fenomena Association 200. IZ Kruga – Vojvodina (Out of Circle Vojvodina) 201. Oasis of Safety (Oaza Sigurnosti) 202. Roma Center for Women and Children - Daj 203. SOS Zenski center – Novi Sad 204. Udruzenje zena femina (Womens Association Femina) 205. Women for Peace (Zene za mer) SLOVAKIA 206. Fenestra SLOVENIA 207. Association for Non Violent Communication
208. Association SOS Help-Line for Women and Children, Victims of Violence SPAIN Experts: 209. Macaena Lopez Anadon 210. Encarna Bodelón Gónzalez. Professor, Filoso del derecho. Universitat Autònoma de Barcelona 211. Maria Jose Gonzalez de la Rosa 212. Professor Soledad Andres Gomez, Universidad de Alcala 213. Salome De Benito 214. Eva Medina Rodriguez 215. Mararita Arribas Martin 216. Carolina Delgardo Garcia 217. Carmen Freixa Zurita 218. Maria Teresa Sanz Hiraldo 219. Emelina Galarza Fernandez 220. Sandra Brizuela Rodriguez 221. Concepcion Diaz Rodriguez 222. Buno Herrero Fernandez 223. Andrea Castillo Diaz 224. Lola Rodriguez Martinez 225. M del Carmen Martinez Martinez 226. Emila Bolinches Ribera 227. Maria Jesus Rodriguez Fernandez 228. Fernando Almodovar Perez 229. Ana Gloria Sanchez Ruano 230. Pillar Capellades Escofet 231. Begona Moraga de la Fuente 232. Carmen Yago 233. Angela Marchante 234. Montserrat Vazquez Peral 235. Veronica Munoz Carrera
236. Alicia Fernandez Perea 237. Maria Teressa Aragon Corrochano 238. Lourdes Ramirez Barranco 239. Aritz Garcia de Cortazar Urzuriaga 240. Rosanio Guerrero 241. Juan Carlos Ruiz Liria 242. Marina Guia Carlon Carminero Institutions 243. AAMM Feministas Marcela Largarde 244. ADIBS (Asociacion de Mujeres para de la Salud Islas Balears 245. AEFI – Asociacion Escuela de Feminismo e Igualdad 246. Alquima Feminista 247. Ascension Dominguez Recios 248. Asociacion con la A 249. Asociacion Damos la cara contra la violencia genero 250. Asociacion de Majures Feminista Puntos Subversivos 251. Asociacion de Mujeres Separadas y Divoria del Pais Valencia 252. Asociacion de Mujures Juristas Themis 253. Asociacion de Mujures LILTH 254. Asocicion Mujures Progresistas Ritino 255. Asociacion de Mujures TIEMAR 256. Asociacion de Psicologia y Psicoterapia Feminista 257. Asociacion Feminista Tiemar 258. Asociacion La Sur-Feminicidio 259. Asociacion Nosotras en el Mundo 260. Asociacion para la Defensa de la Imagen Pu de las Mujer (ADIPN) 261. Asociacion SARAE de desarrollo y cooperac internacional 262. Candelita 263. Centro de Estudios e Investigacion sobre (CEIM) 264. Confederacion Intersindical 265. Custodia en Positivo
266. (DES)ARAMDOS Hombres contra los privileg patrarcales 267. Federacion de Asociaciones de Mujures Laurisilva 268. Federacion de Dones Progressistes CV 269. Federacion Feminista Gloria Arenas 270. Federacion Nacional de Asociaciones de Separadas y Divorciadas 271. Form de Politica Feminista de Granada 272. Forum Feminista de Madrid 273. Marxa Mundial de Donnes Valencia 274. Partido Feminista de Espana 275. Plataforma Abolicionists Canaria 276. Platforma de Madres Feminists por la Ampliacion y la Transferibilidad de los Pemiso (PETRA) 277. Plataforma 7N Madrid 278. Platforma 8M 25N de Granada 279. PLAZANDREOK Feminista 280. Red Caps 281. Revista Majeres y Salud 282. Secretaria Confederal de Majures e lgualdac CCOO 283. Stop Vientres de Alquiler SWITZERLAND 284. Glòria Casas Vila, Postdoctoral Fellow, Université de Lausanne, Switzerland UNITED KINGDOM Experts: 285. Dr Adrienne Barnett, Ph.D., Senior Lecturer – Law, Brunel University, London 286. Jenny Beck, Solicitor, Director of Beck Fitzgerald, LLP 287. Professor Vanessa Bettinson, Professor of Criminal Law and Criminal Justice, De Montford University 288. Estelle de Boulay, Director, Rights of Women, London 289. Professor Shazia Choudhry, Department of Law, Queen Mary University, London
290. Olive Craig, Legal Officer, Rights of Women, London 291. Dr Julie Doughty, Ph.D., Lecturer in Law, Cardiff University School of Law and Politics 292. Professor Gillian Douglas, LL.D., FacSS, Executive Dean, The Dickson Poon School of Law, King’s College London 293. Jane Fortin, Emeritus Professor, University of Sussex 294. Sarbjit Ganger, Director, Asian Women’s Resource Centre, London 295. Mandip Ghai, Legal Officer, Rights of Women, London 296. Lucy Hadley, Campaigns and Public Affairs Manager, Women’s Aid, England 297. Jonathan Herring, Professor of Law, Oxford University, England 298. Marianne Hester, Professor, Chair in Gender, Violence & International Policy, University of Bristol, UK 299. Joan Hunt, OBE, Honorary Professor, Cardiff University, School of Law and Politics 300. Melanie Johnson, Family Law Barrister, 1 Pump Court Chambers, London 301. Felicity Kaganas, Professor of Law, Brunel Law School 302. Mavis MacLean, Senior Research Fellow, University of Oxford 303. Professor Judith Masson, PhD, Professor of Socio-Legal Studies, University of Bristol Law School, University of Bristol 304. Dr Nina Maxwell, PhD, Senior Research Associate, Cardiff University School of Social Sciences 305. Professor Lorraine Radford, Phd, Professor of Social Policy and Social Work, University of Central Lancashire 306. Ruby Sayed, Chair of the Asian Women’s Resource Centre, Councillor City of London Farringdon Ware 307. Naomi Scarano, Family Law Barrister, London 308. Dr Thomas Slater, PhD, Lecturer in Social Work, Cardiff University School of Social Sciences 309. Dr Leanne Smith, PhD, Senior Lecturer in Law, Cardiff University School of Law and Politics 310. Dr Liza Thompson, PhD, CEO of Sateda, UK 311. Professor Liz Trinder, University of Exeter 312. Suzanne Zaccour, Dphil student in law, Oxford University, Oxford, United Kingdom Institution: 313. Scottish Womens Aid 314. Welsh Womens Aid
UKRAINE 315. Center for Womens Perspectives UNITED STATES Experts 316. Caroline Bettinger-López, Professor of Clinical Legal Education, Director, Human Rights Clinic, University of Miami Law School 317. Kelly M Champion, PhD, Clinical and Forensic Psychologist, American Board Certified in Clinical Child & Adolescent Psychology, Maryland, LP, Iowa, LP, HSP, Massachusetts LP, HSP, Cadeus Behavioral Health, 199 E. Montgomery Ave. Suite 100, Rockville MD 20850318. Dr. David L. Corwin, MD, Child and Forensic Psychiatrist, Professor (Clinical) Pediatrics, University of Utah, founding member and current President of the American Professional Society on the Abuse of Children (APSAC), founder of California Professional Society on the Abuse of Children, the Helfer Society and the Academy of Violence and Abuse and the first Chair of the National Health Collaborative on Violence and Abuse. Cynthia Cummings, Attorney, Child Justice Inc. Silver Spring, MDMargaret Drew, Associate Professor, University of Massachusetts Law SchoolSasha Drobnick, Managing Attorney, Domestic Violence Legal Empowerment and AppealsProject (DV LEAP)322. Dr Jeffrey L. Edleson, Ph.D., Dean, School of Social Welfare, University of California, Berkeley, CaliforniaNancy S. Erickson, J.D., LL.M., M.A, Brooklin, New York.Dr. Kathleen Coulborn Faller, Ph.D., A.C.S.W., Marion Elizabeth Blue Professor Emerita ofChildren and Families, School of Social Work, University Of Michigan325. Lisa Fischel-Wolovick, JD, MSW, Adj. Associate Professor, Department of Psychology, City University of New York at John Jay College326. Denise Gamache, MSW, Executive Director, Battered Women’s Justice Project, Minneapolis. The Project also manages the National Center on Protection Orders and Full Faith Credit327. Dr Robert Geffner, Ph.D., ABN, ABP, Founding President, Institute on Violence, Abuse and Trauma, Distinguished Research Professor of Psychology, Alliant International University, San DiegoPaul Griffin, Legal Director, Child Justice Inc., Silver Spring, MDNathaniel Grube, Attorney, Child Justice Inc., Silver Spring, MDDr. Jennifer Leann Hardesty, PhD, Professor, Human Development and Family Studies,University of Illinois
331. Eileen King, E.D., Program Director, Child Justice Inc., Silver Spring MD 332. Dr Jean Mercer, PhD, Professor Emerita, Psychology, Stockton University, New Jersey and Founding Fellow, Institute for Science in Medicine 333. Joan Meier, Professor of Law, George Washington University Law School and Legal Director, Domestic Violence Legal Empowerment and Appeals Project (DV LEAP); 334. Sandi Capuano Morrison, Chief Executive Officer, Institute on Violence, Abuse and Trauma (IVAT); Board Member, National Partnership to End Interpersonal Violence Across the Lifespan (NPEIV) San Diego 335. Gimel Rogers, Psy.D, Training Director, IVAT 336. Linda Rosa, RN, Executive Director, Advocates for Children in Therapy, Loveland, Colorado 337. Kathleen Russell, Executive Director, Center for Judicial Excellence, California 338. Aileen Herlinda Sandoval, Psy.D., Forensic Associate, Institute on Violence, Abuse and Trauma (IVAT) and Family Violence and Sexual Assault Institute (FVSAI), San Diego 339. Alexandra Sandacz, Attorney, Child Justice Inc., Silver Spring, MD 340. Dr Daniel Saunders, Ph.D., Professor Emeritus, School of Social Work, University of Michigan 341. Lynn Hecht Schafran, Legal Director, National Judicial Education Program, The Women’s Legal Defense and Education Fund 342. Morgan Shaw, Psy.D, Clinical Director, Institute on Violence, Abuse & Trauma, San Diego 343. Sudha Shetty, Esq., Assistant Dean, International Alliances & Partnerships and Director, Hague Domestic Violence Project, Goldman School of Public Policy, University of CA, Berkeley 344. Dr Evan Stark, Ph.D, MSW, Professor Emeritus, Rutgers University 345. Esta Soler, President, Futures Without Violence, San Francisco, Washington, Boston 346. Dr. Sarah Trane, PhD, Pediatric Psychologist, Mayo Clinic Health System, La Crosse, Wisconsin 347. Connie Valentine, California Protective Parents Association, 348. Merle Weiner, Philip H. Knight Professor of Law, University of Oregon 349. Jennifer White, Program Director, Futures Without Violence, San Francisco, Washington, Boston Institutional Endorsements: 350. Advocates for Children in Therapy, Loveland, Colorado 351. American Professional Society on the Abuse of Children, Columbus, Ohio 352. Legal Momentum, the Women’s Legal Defense and Education Fund, New York