Why Parents Who Batter Win Custody
by Sarah Childress
It took six years for Genia Shockome to gather the courage to leave her husband, Tim. He pushed her, kicked her and insulted her almost from the moment they married in 1994, she says. She tried to start over with their children when the family moved from Texas to Poughkeepsie, N.Y. It didn't last long. Tim called her constantly at work and, after they split up, pounded on her door and screamed obscenities, she alleged in a complaint filed in 2001. Tim was charged with harassment. As part of a plea deal, Tim agreed to a stay-away order—but denies ever abusing her or the children. In custody hearings over the past six years, Tim has insisted that he's been a good father, and argued that Genia's allegations poisoned their children against him. The judge sided with Tim. This summer he was granted full custody of the kids, now 11 and 9. Genia was barred from contacting them.
Genia is one of many parents nationwide who have lost custody due to a controversial concept known as parental alienation. Under the theory, children fear or reject one parent because they have been corrupted or coached to lie by the other. Parental alienation is now the leading defense for parents accused of abuse in custody cases, according to domestic-violence advocates. And it's working. The few current studies done on the subject consider only small samples. But according to one 2004 survey in Massachusetts by Harvard's Jay Silverman, 54 percent of custody cases involving documented spousal abuse were decided in favor of the alleged batterers. Parental alienation was used as an argument in nearly every case.
This year the National Council of Juvenile and Family Court Judges denounced the theory as "junk science," and at least four states have passed legislation to curtail its use in custody cases involving allegations of domestic violence. "It's really been a cancer in the family courts," says Richard Ducote, an attorney in Pittsburgh who has represented abuse victims in custody cases for 22 years. "It's made it really difficult for parents to protect their kids. If you ask for protection, you're deemed a vindictive, alienating parent."
It may seem hard to fathom how a judge could award custody to a parent accused of abuse. But battered spouses often don't file criminal charges—so no judicial finding is made against their mates—and family-court judges typically aren't trained to referee the complexities of abusive relationships. (Although men are sometimes battered by their wives, women are the victims in the majority of abuse cases.) Judges often throw out documented evidence of spousal abuse, arguing that it is irrelevant in a custody case. And experts say that family-court judges often look favorably on the alleged abuser because he seems more willing to share custody than the accuser—who is hellbent on keeping the father away from the child. According to a survey by Geraldine Stahly, a psychology professor at California State University at San Bernardino, attorneys will caution battered spouses against reporting abuse in court so they don't lose their children. (Stahly and other academics say the parental-alienation argument has more legitimacy in custody disputes that don't involve charges of abuse.)
Parental-alienation syndrome was first introduced by child psychiatrist Richard Gardner in the 1980s. Fathers-rights groups picked up on the idea and began trying it out in court. These groups condemn abusers. But Dan Hogan, executive director of Fathers & Families, a nonprofit group that advocates for joint custody, argues that all too often the accusers lie in order to win custody of their kids.
There's a small but growing movement to ban parental alienation in custody cases, sparked by embattled parents bonding online. They've linked with lawyers and advocates for battered spouses across the country. At least four states, including California, have laws protecting parents who make good-faith abuse allegations. Others may soon follow their lead. Greg Jacob, an attorney who takes cases for abused parents pro bono, is drafting legislation to shop to Virginia and Maryland next month. Meanwhile, parents like Genia keep fighting. "It's so hard, having my children lost," she says, her voice breaking. "This was my life—my children."
“Domestic violence is about control, not anger. Once a victim says ‘I’m leaving you,’ the last thing the batterer has over the victim is the children,” Katie Foster, regional training coordinator for the family violence division of the Dallas County district attorney’s office. Family violence issue at seminar: Dallas: Parental alienation syndrome leads conference. The Dallas Morning News (10-27-2006).
“Domestic violence is about control, not anger. Once a victim says ‘I’m leaving you,’ the last thing the batterer has over the victim is the children,” Katie Foster, regional training coordinator for the family violence division of the Dallas County district attorney’s office. Family violence issue at seminar: Dallas: Parental alienation syndrome leads conference. The Dallas Morning News (10-27-2006).
“Domestic violence is about control, not anger. Once a victim says ‘I’m leaving you,’ the last thing the batterer has over the victim is the children,” Katie Foster, regional training coordinator for the family violence division of the Dallas County district attorney’s office. Family violence issue at seminar: Dallas: Parental alienation syndrome leads conference. The Dallas Morning News (10-27-2006).
“Domestic violence is about control, not anger. Once a victim says ‘I’m leaving you,’ the last thing the batterer has over the victim is the children,” Katie Foster, regional training coordinator for the family violence division of the Dallas County district attorney’s office. Family violence issue at seminar: Dallas: Parental alienation syndrome leads conference. The Dallas Morning News (10-27-2006).
“When mental health experts or attorneys claim that P.A.S. is a ’syndrome’– knowing full well that it lacks scientific validity, is the concoction of a disgraced psychologist, and has been soundly rejected by the National Council of Juvenile and Family Court Judges — that is disingenuous at best and unethical at worst. Moreover, when it is used as a vehicle to keep children in the custody of men who abuse them, it is also immoral. ” , Randy Burton, Founder, Chairman and President - Justice for Children. http://www.jfcadvocacy.org/pas.asp
“PAS is not research-based, and it has done a great injustice to the family and the justice system. The criteria that Dr. Gardner has developed are virtually useless. He operates on the premise that if you say a lie often enough people will believe it.”, Jon Conte, a psychologist at the University of Washington. “Has Psychiatry Gone Psycho?” by Kelly Patricia O’Meara. Insight on the News (4-26-199)http://findarticles.com/p/articles/mi_m1571/is_15_15/ai_54451069/pg_1
“The vast majority of these mothers (97%) reported that court personnel ignored or minimized reports of abuse. They reported feeling that they were punished for trying to protect their children and 65% said they were threatened with sanctions if the “talked publicly” about the case. In all, 45% of the mothers say they were labeled as having Parental Alienation Syndrome (PAS). The protective parents reported that the average cost of the court proceedings was over $80,000. Over a quarter of the protective parents say they were forced to file bankruptcy as a result of filing for custody of their children. Eighty-five percent of the protective parents surveyed believe that their children are still being abused; however, 63% say they stopped reporting the abuse for fear that contact with their children will be terminated. Eleven percent of the children were reported to have attempted suicide.” “Myths That Place Children At Risk During Custody Litigation”. Dallam. S. J., & Silberg, J. L. (Jan/Feb 2006). Leadership Council. Sexual Assault Report, 9(3), 33-47. http://www.leadershipcouncil.org/1/res/cust_myths.html
“In contrast to the empirically unsupported notion of Parental Alienation Syndrome, these more complex multidimensional models have received preliminary research support. A comprehensive assessment identifying reasons for rejection is critical, because it provides the basis for appropriate intervention. If a parent is being rejected primarily for reasons such as moralistic thinking by the children (e.g., tied to developmental stage), lack of resources (e.g., not as many toys as the other parent’s house), and negative comments by the custodial parent, then therapeutic intervention to rebuild the relationship between the rejected parent and children would be indicated. In contrast, if a careful assessment found that rejection was more closely tied to the non–custodial parent’s history of violence and continued attempts to monitor and harassthe children and primary caregiver, then interventions to create safety for the children and caregiver would be more important that treating the ‘alienation.’”“Making appropriate parenting arrangements in family violence cases: applying the literature to identify promising practices. 2005–FCY–3E.” Research Report, Department of Justice, Canada.http://www.justice.gc.ca/en/ps/pad/reports/2005-FCY-3/chap4.html#4_3
“It is also worth noting that Dr. Gardner often expressed disdain for child abuse professionals, labeling them “validators,” theorizing that greed and desire for increased business prompted some sexual abuse allegations, and speculating that parents and professionals alike made some false allegations because “all of us have some pedophilia within us.” “Parental Alienation Syndrome: What Professionals Need to Know Part 1″. By Erika Rivera Ragland1 & Hope Fields. http://www.ndaa.org/publications/newsletters/update_volume_16_number_6_2003.html#
“PAS does not meet the courts’ threshold requirement to qualify as scientific. Clearly then, the offering of PAS to the courts as an explanatory construct, let alone a basis for making recommendation about the future of children’s lives, does not meet the minimal set of ethical standards incumbent on experts appearing before the court….Because his (Dr. Richard Gardner’s) theories are based on his clinical observations (not on scientific data) they should be understood in the context of his atypical views concerning parent child relations..”“Parental Alienation Syndrome: Frye v Gardner in the Family Courts (Part 2)” By Jerome H. Poliacoff, Ph.D., P.A., Cynthia L. Greene, Esq., and Laura Smith, Esq (Article also includes alternative factors to PAS, caselaw in various states, and in depth research)http://expertpages.com/news/parental_alienation_syndrome2.htm
Dr. Paul Fink, a professor of psychiatry at Temple University School of Medicine and a past president of the American Psychiatric Association in Arlington, Va quotes on PAS include:“This is junk science”“He (Dr. Gardner) invented a concept and talked as if it were proven science. It’s not.”“There are lots of people who alienate their partners during a divorce, But it is not a syndrome, a disease or a disorder.”“Richard Gardner and Parental Alienation Syndrome: The debate rages on…”. By Jamie Talan, Newsday.com, July 1, 2003. http://www.ipce.info/library_3/files/pasyndrome.htm
“In 1996 a leading task force of the APA published a widely disseminated and relied-upon report: Titled ‘Violence and the Family,’ written by the American Psychological Association Presidential Task Force on Violence and the Family, and published by the American Psychological Association, it is based on a comprehensive review of the literature and research on violence in the family.
The Report states, among other things:
‘When children reject their abusive fathers, it is common for the batterer and others to blame the mother for alienating the children. They often do not understand the legitimate fears of the child. Although there are no data to support the phenomenon called parental alienation syndrome, in which mothers are blamed for interfering with their children’s attachment to their fathers, the term is still used by some evaluators and courts to discount children’s fears in hostile and psychologically abusive situations.” (page 40) “THE TRUTH ABOUT PARENTAL ALIENATION SYNDROME AND THE AMERICAN PSYCHOLOGICAL ASSOCIATION”. Statement by Professor Joan S. Meier, Esq. (November 9, 2005). Compiled by Trish Wilson, 2005. Trish Wilson offers alot of articles and resources on her site,http://members.aol.com/asherah/meier1.html
“It is interesting that Gardner advocates severing the relationship between a child and a mother who he considers to be emotionally abusive, yet he stresses maintaining and building the relationship whenever possible with fathers who have been found to have sexually abused their child. For example, in reference to sexually abusive fathers, Gardner (1992b, p. 572) states: “There is no such thing as a parent who is perfect .. The sexual exploitation has to be put on the negative list, but positives as well must be appreciated (by the child)..” “The Parental Alienation Syndrome: Is It Scientific?” by Stephanie J. Dallam, RN, MSN, FNP, The Leadership Council. http://www.leadershipcouncil.org/1/res/dallam/3.html
“WORLD reviewed histories on 13 PAS cases—in California, Texas, New York, North Carolina, Georgia, Utah, and other states. These cases had something in common: documentation. In all 13 cases, court records show the mother had already been found a fit parent, and was in most cases already the primary custodial parent. In all 13, court-appointed psychologists ignored children’s testimony of sexual abuse, and in some cases, medical findings of abuse, and even previous sex-offender violations. And in all 13 cases, court-appointed mediators concluded that the mothers had inculcated PAS in their children and recommended Dr. Gardner’s standard prescription: to strip custody from the mother and place the child with the father for ‘deprogramming.’” “Little girls lost?: Embraced in family courts across the country, a controversial “syndrome” may be placing abused children at risk” by Lynn Vincent. WORLD Magazine (2-08-2003). http://www.worldmag.com/articles/6825
“PAS has no credibility, validity or utility in the respective medical or child protection communities and in accordance with the Queensland Supreme Court ruling, the use of the label in judicial proceedings could be viewed as prejudicial to those proceedings in the absence of factual evidence and makes a presumption of guilt of the accused residency parent which it is proper for a Court to decide on the basis of factual evidence.It is seriously flawed reasoning which assumes that a child is being untruthful about abuse without a very careful and thorough investigation of the child’s allegations and an examination of the corroborative evidence and that a parent is misrepresenting or falsely presenting the allegations of the child. When children make a report or disclosure that they have been abused, what they say must never be dismissed, ignored, or disregarded by any adult but should be carefully listened to and inquiries made to establish corroborative evidence, much of which can be found in changes in their moods, temperament, and behaviours.”, Charles Pragnell, Expert Witness in Child Protection in the U.K. and Australasia, and a Child/Family Advocate.”Parental Alienation Syndrome Leading.” Child WebMag. http://www.childrenwebmag.com/content/view/280
“Parental alienation happens, but there’s no clinical syndrome you can say in court and get away with. Richard Gardner was a charlatan, and hundreds of women and children across the country have been damaged because of his crazy idea. PAS is not in the DSM-IV and it never will be.”, Paul Jay Fink, professor of psychiatry at Temple University School of Medicine. When a Bad Divorce Gets Ugly: Baldwin call may reflect alienation, The San Diego Union-Tribune (5-13-2007). By Melissa Fletcher Stoeltje.
http://www.signonsandiego.com/uniontrib/20070513/news_1c13alien.html
This man is SICK!!! Any group that aligns themselves with him is just as sick. PAS was created as a way to excuse child molestation and pedophilia...
Gardner attempts to blame the child for the abuse, the male parent is always a victim. Either a victim of the mother or the child. When is society going to make people take responsibility for their actions?
I, personally, think that Gardner has a serious inferiority complex when it comes to issues with women. This is why he write what he does and says what he does. The question is the judges and so called experts, such as Julie Skakoon, Diana Vigil and John Moran who subscribe to this garbage, what is their objective?
To align oneself with an organization that is basically seeking to make pedophilia and child rape acceptable makes me think that these judges are somehow part of these groups. Any one who wants to force society to accept this behavior must participate.
Quotes by Richard Gardner
Gardner on the sexual aggressiveness of children Gardner suggests that children want to have sex with adults and may seduce them.
Some children experience " high sexual urges in early infancy. " "There is good reason to believe that most, if not all, children have the capacity to reach orgasm at the time they are born." Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse .Cresskill, NJ: Creative Therapeutics. (p. 15)
Children are naturally sexual and may initiate sexual encounters by "seducing" the adult . Gardner, R.A. (1986). Child Custody Litigation: A Guide for Parents and Mental Health Professionals. Cresskill, NJ: Creative Therapeutics (p. 93).
If the sexual relationship is discovered, " the child is likely to fabricate so that the adult will be blamed for the initiation ." Gardner, R.A. (1986). Child Custody Litigation: A Guide for Parents and Mental Health Professionals. Cresskill, NJ: Creative Therapeutics (p. 93).
"The normal child exhibits a wide variety of sexual fantasies and behaviors, many of which would be labeled as 'sick' or 'perverted' if exhibited by adults" Gardner, R.A. (1991). Sex Abuse Hysteria: Salem Witch Trials Revisited . Cresskill, NJ: Creative Therapeutics. (p. 12)
Sex abuse is not necessarily traumatic; the determinant as to whether sexual molestation will be traumatic to the child, is the social attitude toward these encounters. Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics. (pp. 670-71)
Gardner on therapy with children who are sexually abused by their father
• Keep the child connected to the abuser Special care should be taken not alienate the child from the molesting parent. The removal of a pedophilic parent from the home "should only be seriously considered after all attempts at treatment of the pedophilia and rapprochement with the family have proven futile." Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics.(p. 537)
The child should be told that there is no such thing as a perfect parent. "The sexual exploitation has to be put on the negative list, but positives as well must be appreciated" Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics.(p. 572)
• Tell the child that sexual abuse by a father is normal Older children may be helped to appreciate that sexual encounters between an adult and a child are not universally considered to be reprehensible acts. The child might be told about other societies in which such behavior was and is considered normal. The child might be helped to appreciate the wisdom of Shakespeare's Hamlet, who said, "Nothing's either good or bad, but thinking makes it so." Gardner, R.A. (1992). True and False
Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics.(p. 549)
"In such discussions the child has to be helped to appreciate that we have in our society an exaggeratedly punitive and moralistic attitude about adult-child sexual encounters"
Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics.(p. 572).
Gardner on mothers who discover that their husband is sexually abusing their child Gardner blames the father's abuse on the mother, who he faults for not fulfilling her husband sexually. He suggests that therapists should help mother's of incest victims achieve sexual gratification.
• Discourage litigation.
• Encourage her to stay with her husband (the abuser)
• Blame her and the daughter for the sexual abuse by the father
"It may be that one of the reasons the daughter turned toward the father is the
impairment of the child's relationship with the mother" (pp. 579-80) Gardner, R.A.(1992). True and False Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics. (p. 585)
• Help her get over her anger at her husband for sexually abusing their child. "If the mother has reacted to the abuse in a hysterical fashion, or used it as an excuse for a campaign of denigration of the father, then the therapist does well to try and "sober her up".... Her hysterics ... will contribute to the child's feeling that a heinous crime has been committed and will thereby lessen the likelihood of any kind of rapproachment with the father. One has to do everything possible to help her put the "crime" in proper perspective. She has to be helped to appreciate that in most
societies in the history of the world, such behavior was ubiquitous [i.e., everywhere], and this is still the case."
Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics. (pp. 576-7)
"Perhaps she can be helped to appreciate that in the history of the world his behavior has probably been more common than the restrained behavior of those who do not sexually abuse their children." Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics. (pp. 585)
• Encourage her to become more sexually responsive to her husband.
"Her increased sexuality may lessen the need for her husband to return to their daughter for sexual gratification." "Verbal statements about the pleasures of orgastic response are not likely to prove very useful. One has to encourage experiences, under proper situations of relaxation, which will enable her to achieve the goal of orgastic response." "One must try to overcome any inhibition she may have with regard to [the use of vibrators]." "Her own diminished guilt over masturbation will make it easier for her to encourage the practice in her daughter, if this is warranted. And her increased sexuality may lessen the need for her husband to return to their daughter for sexual gratification."
Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics. (p. 585)
Gardner on fathers who sexually abuse their children
• Tell him what he did his normal "He has to be helped to appreciate that, even today, it [pedophilia] is a widespread and accepted practice among literally billions of people. He has to appreciate that in our Western society especially, we take a very punitive and moralistic attitude toward such inclinations. He has had a certain amount of back (sic) luck with regard to the place and time he was born with regard to social attitudes toward pedophilia."
Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics. (p. 593)
He has had bad luck with regard to the place and time he was born with regard to social attitudes toward pedophilia. However, these are not reasons to condemn himself. Gardner, R.A. (1991). Sex Abuse Hysteria: Salem Witch Trials Revisited . Cresskill, NJ: Creative Therapeutics. (p. 119)
• Keep him in the home
The removal of a pedophilic parent from the home "should only be seriously considered after all attempts at treatment of the pedophilia and rapprochement with the family have proven futile" Gardner, R.A. (1991). Sex Abuse Hysteria: Salem WitchTrials Revisited . Cresskill, NJ: Creative Therapeutics. (p. 119)
• Help him protect himself
"He must learn to control himself if he is to protect himself from the Draconian punishments meted out to those in our society who act out their pedophilic impulses."
Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse . Cresskill , NJ: Creative Therapeutics. (pp. 585-592)
• Help him forget about it
Therapy with the father should not be spent focusing on the primary problem (I.e.,
sexual molestation). Instead, therapy should be spent "talking about other things"
as the goal of therapy is "to help people forget about their problems"
Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics. (pp. 585-592)
Gardner on how society should respond to the widespread victimization of children Take a more sympathetic view toward pedophilia "One of the steps that society must take to deal with the present hysteria is to 'come
off it' and take a more realistic attitude toward pedophilic behavior." (p. 120)
"The Draconian punishments meted out to pedophiles .go far beyond what I consider to be the gravity of the crime." (p. 118) Gardner, R.A. (1991). Sex Abuse Hysteria: Salem Witch Trials Revisited. Cresskill, NJ: Creative Therapeutics.Abolish mandated reporting of child sexual abuse.
Do away with immunity for reporters of child abuse.
Create federally-funded programs to assist those claiming to have been falsely accused of child sexual abuse.
Gardner, R.A. (1995). Written testimony on HR3588 - Proposed revision of the child abuse prevention and treatment act (CAPTA) (Public Law 93-247).
• Keep pedophiles in the community
The removal of a pedophilic parent from the home "should only be seriously considered after all attempts at treatment of the pedophilia and rapproachment with the family have proven futile" Pedophiles who abuse children outside of the home should first be given the opportunity for community treatment. "If that fails then and only then should some
kind of forced incarceration be considered" Gardner, R.A. (1991). Sex Abuse
Hysteria: Salem Witch Trials Revisited . Cresskill, NJ: Creative Therapeutics. (p. 119)
Gardner on Child abuse hysteria
Child abuse allegations are the "third-greatest wave of hysteria" the nation has seen, following the Salem witch trials and the McCarthyite persecution of leftists. Gardner, R.A. (1993, February 22). Modern witch hunt--child abuse charges. The Wall Street Journal, p. A10.
"We are currently living in dangerous times, similar to Nazi Germany. Sexual abuse hysteria is omnipresent." Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics. (p. xxv)
Who is to Blame for "Child Abuse Hysteria"?
• People who voice negative feelings against pedophiles
"During their harangues against the 'perverts' who are the objects of their scorn, they often rise to a level of excitation that can readily be seen as sexual. . . .Psychological, such individuals are ever fighting to repress their own unacceptable pedophilic impulses, which are continually pressing for release." Gardner, R.A.(1991). Sex Abuse Hysteria: Salem Witch Trials Revisited . Cresskill, NJ: Creative Therapeutics (pp. 30-31).
• The legal system - including judges
"There is no question that abuse cases are "turn ons" for the wide variety of individuals involved in them, the accuser(s), the prosecutors, the lawyers, the judges , the evaluators, the psychologists, the reporters, the readers of the newspapers, and everyone else involved - except for the falsely accused and the innocent victim ..Everyone is getting their 'jollies, ." Gardner, R.A. (1991). Sex Abuse Hysteria: Salem
Witch Trials Revisited . Cresskill, NJ: Creative Therapeutics. (p. 31).
"Judges . too may have repressed pedophilic impulses over which there is
suppression, repression, and guilt. Inquiry into the details of the case provides voyeuristic and vicarious gratifications .. Incarcerating the alleged perpetrator may serve psychologically to obliterate the judge's own projected pedophilic impulses."Gardner, R.A. (1991). Sex Abuse Hysteria: Salem Witch Trials Revisited .Cresskill, NJ: Creative Therapeutics. (p. 107)
• Sexually inhibited mothers
"The mother . is . psychologically gratifying [her own sexually inhibited needs] with the visual imagery that the sex abuse allegation provides." Gardner, R.A. (1991). Sex Abuse Hysteria: Salem Witch Trials Revisited . Cresskill, NJ: Creative Therapeutics (pp.36-37).
• Greedy parents
"Many are victims of their greed, which is so enormous that they blind themselves to the psychological traumas they are subjecting their children to in the service of winning lawsuits that promise them enormous wealth." Gardner, R.A. (1991). Sex Abuse Hysteria: Salem Witch Trials Revisited . Cresskill, NJ:Creative Therapeutics (p 43).
• Judeo-Christian principles
"It is of interest that of all the ancient peoples it may very well be that the Jews were the only ones who were punitive toward pedophiles.. Our present overreaction to pedophilia represents an exaggeration of Judeo-Christian principles and is a significant factor operative in Western society's atypicality with regard to such activities Gardner, R.A. (1992). True and False Accusations of Child Sex Abuse . Cresskill, NJ: Creative Therapeutics. (pp. 46-7
Notice how Gardner puts the blame completely on the woman. Be it child or mother. I would like for someone to explain to me at what age does the child start seducing the parent? Fathers are sexually molesting and killing babies - children that are only a few months old. How can a child be actively seducing an adult at this age?
