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That PAS has not gained acceptance in the relevant scientific community is not seriously in dispute (Dallam, Parental Alienation Syndrome: Is it scientific?, 1999).
As early as 1996, the Report of the American Psychological Association Presidential Task Force on Violence and the Family stated that:
"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….Family courts often do not consider the history of violence between the parents in making custody and visitation decisions. . . . Psychological evaluators not trained in domestic violence may contribute to this process by ignoring or minimizing the violence and by giving inappropriate pathological labels to women's responses to chronic victimization. Terms such as 'parental alienation' may be used to blame the women for the children's reasonable fear of or anger toward their violent father."
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American Psychological Association, Violence and the Family: Report of the American Psychological Association Presidential Task Force on Violence and the Family (1996) at 22, available
here.
Several courts, therefore, recognizing that admission of scientifically disputed evidence would not meet the standards of Frye and Daubert, have barred evidence concerning PAS. See, e.g., Page v. Zordan 564 So. 2d 500, 1990 Fla. App. LEXIS 3234; People v. Loomis 172 Misc. 2d 265, 658 N.Y.S. 2d 787, 1997 N.Y. Misc. LEXIS 141; People v. Fortin, 184 Misc. 2d 10; 706 N.Y.S.2d 611, 2000 N.Y. Misc. LEXIS 88 (2000).
In 2006, the Connecticut Superior Court held in Snyder v. Cedar, 2006 Conn. Super. LEXIS 520 (2006), *28-*29:
"The court finds that "parental alienation syndrome" has no scientific validity at this time. There is no credible evidence that "parental alienation syndrome"; as defined or described by [the social worker], or that the “[Sex Abuse in Divorce]" phenomenon, has been recognized within any of the mental health professions. Most importantly, in reference to our current case law, the diagnosis of parental alienation syndrome and the identification of the perpetrator of such an affliction lacks any methodological underpinning. When the methodology underlying proferred [sic] evidence is sufficiently invalid to render the evidence incapable of helping the fact finder determine a fact in dispute, such evidence is inadmissable [sic]."
