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27 Women's Rts. L. Rep. 153 (2006)
Extreme Consequence of Parental Alienation Syndrome - The Richard Lohstroh Case of a Child Driven to Kill His Father - Will Courts Move toward Allowing Children to Use Parental Alienation Syndrome as a Defense to the Crime of Murder of Their Own Parent, The

handle is hein.journals/worts27 and id is 159 raw text is: ARTICLE

The Extreme Consequence of
Parental Alienation Syndrome

Richard Lohstroh Case of a Child

Driven to Kill His Father

- Will

Courts Move Toward Allowing
Children to Use Parental Alienation
Syndrome as a Defense to the Crime
of Murder of Their Own Parent?
April J. Walker*

I. INTRODUCTION
Nothing stirs up passions more for a child
than high-conflict fighting between his or her
parents.1 Such fighting between parents may
range from long-term constant battling, involv-
ing abuse of one parent during the course of the
marriage, to pre- and post-separation divorce

*The author is an Associate Professor at Thurgood
Marshall School of Law at Texas Southern University in
Houston, Texas. Professor Walker is also an associate judge
with the City of Houston Municipal Court System. Thank
you to Professor Larry Weeden and Professor Docia Rudley
for their support and encouragement.
1. See JAYNE A. MAJOR, PARENTS WHO HAVE SUCCESS-
FULLY FOUGHT PARENTAL ALIENATION SYNDROME 2
(Breakthrough Parenting Services, Inc. 2002-2005), available
at http://www.breakthroughparentingservices.org/article-pas.
pdf.
2. See id.
3. See id. at 2, 6.

bickering.2 These high-conflict events render
all of the parties irrational, to some degree.3
Associated with these situations is the tendency
of one parent to brainwash the child with the
intent of alienating the child against the other
parent.4 Additionally, witnessing the abuse of a
parent, can cause the child to alienate the abu-
sive parent.5 This phenomenon is known as Pa-

4. Reena Sommer, How to Cope with the Effects of Paren-
tal Alienation, SOLUTIONs4PAS, http://www.solutions4pas.
com/pas-consult.html (last visited Nov. 7, 2006). See also
Richard A. Gardner, Recent Trends in Divorce and Custody
Litigation, 29 ACADEMY FORUM 3, 3-7 (1985), available at
http://www.fact.on.ca/Info/pas/gardnr85.htm  (last visited
Nov. 7, 2006) [hereinafter Gardner, Recent Trends].
5. See generally Daniel J. Rybicki, Parental Alienation and
Enmeshment Issues in Child Custody Cases, EXPERT WIT-
NESS TESTIMONY & FORENSIC PSYCHOLOGY (forthcoming),
available at http://www.fact.on.ca/Info/pas/rybick0O.htm (last
visited Nov. 7, 2006). See also Richard A. Warshak, Remar-
riage as a Trigger of Parental Alienation Syndrome, 28 AM. J.

[Women's Rights Law Reporter, Volume 27, Number 3, Summer 2006]
© 2007 by Women's Rights Law Reporter, Rutgers-The State University
0085-8269/80/0908

The

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