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Concerned About Unconventional Mental Health Interventions?

Concerned About Unconventional Mental Health Interventions?
Alternative Psychotherapies: Evaluating Unconventional Mental Health Treatments

Thursday, January 10, 2019

Legal Resident vs Undocumented Resident: Thinking Critically About Who Kills Whom


Ordinarily I avoid on this blog topics that are obviously political in nature—even though anything connected with child care and child welfare is highly value-laden and therefore has strong political implications. However, I can no longer resist commenting on some critical thinking issues about discussions of killings by undocumented migrants.

In the last year or two, there have been several much-discussed events in which a person later discovered to be in the United States illegally has killed another person who was a legal resident of the country. These facts have been used as part of arguments against admitting most immigrants and in favor of draconian measures against undocumented persons already in the U.S.

Is it legitimate to reason from the killings to the positions taken by the people who advocate for much stricter anti-immigration measures? There are actually two ways we can think about this.

The first approach we might make to the making of a connection between killings by undocumented immigrants and severe immigration policies involves the idea of “the canary in the coal mine”. When little information about a danger is available , it can be the case that unusual attention should be paid to a few anecdotes. Although ordinarily psychologists assign little weight to anecdotal information, an important 2010 paper by Dimidjian and Hollon poited out that with respect to adverse events, attention to anecdotes may be the first line of defense. Anecdotes can alert us to potential problems, which can then be given systematic study. In cases where there are serious but rare problems that we would like to prevent, we might never notice such infrequent events without considering anecdotes, as the great preponderance of the information would “wash out” the problems statistically. This does not, of course, imply that we can generalize freely from a small number of anecdotes—it only means that anecdotes can guide our attention to risks that we might not otherwise notice. Without systematic study, even a large number of anecdotes can only give us proof of concept (as I am trying to argue in a paper I am presently working on, which involves about 50 anecdotes).

The second approach involves thinking through all of the possible events and looking at them in terms of the proportion each makes up of the whole set of events of interest. In the case of the migrant=killer argument stated earlier, there are two variables that can be used to categorize events. People may be classified according to their legal status in the United States (i.e., legal resident or undocumented resident). They may also be classified as to their involvement in a murder, either killing or being killed. This sets aside the great majority of the population, who, whatever their residence status, have not killed anyone, nor have they been killed.

Focusing our attention only on the small proportion of people who have killed or been killed, we see that there are four possible categories they may fall into: 1. Legal residents who have killed other legal residents; 2. Legal residents who have  killed undocumented residents; 3. Undocumented residents who have killed other undocumented residents; and 4. Undocumented residents who have killed legal residents. The argument that undocumented residents are killers has been based only on the fourth category, undocumented residents who have killed legal residents. And you can create a table with four categories of interest, each of which needs to have a number filled in if we are going to use them to support any argument. (However, I apparently can't, because every time I try to post what I've done, the lines get scrambled, and I am giving it up.) 

     

The conclusions we could draw—IF we had the numbers to plug into our table—would have to take account of proportions of people, not of absolute numbers. There are a lot more legal residents than there are undocumented residents, so we would expect more of the killings to be done by legal residents, and we would learn something from this analysis only if we look at the rates (number of killings compared to the total number of killers) for each category.

So what are the possible conclusions that we could draw from the completed table, if we had the numbers to fill it in? We might conclude that legal residents kill other legal residents at a higher rate than we see in the other categories--  or that legal residents are more likely to kill undocumented residents—or that undocumented residents are more likely to kill each other—or, what has recently been claimed, that undocumented residents have a high rate of killing legal residents.

Whatever the outcome and the policy argument it supports, we can’t figure it out until we have all the information required. The existence of a few anecdotes may encourage us to do this work, but until it is done, no conclusion is possible. 

Wednesday, January 2, 2019

Attachment: Important, Yes, But not the Only Factor, Especially in the Workplace


Emotional development, cognitive development, personality development—even physical development—result from a lot of factors working simultaneously. Trying to choose one factor and make it do all the work is sort of like trying to claim that the condition of the tires is the one thing that determines how the car operates. Even if we’re not mechanics, it’s obvious to us that any one of dozens of items can make a car hard or impossible to drive—yet when it comes to thinking about how children develop into adults, it’s all too easy to focus exclusively on a single process or event.

 For  a number of years now, the single developmental factor that has received most attention in popular thinking has been attachment--  the internal state that underlies toddlers’ wish to be close to familiar people and their anxiety about separation and that seems to help shape their later perspectives on social relationships. Toddlers can be categorized as having different qualities of attachment behavior, and those different qualities are sometimes called attachment “styles”. Although trauma (broadly defined) is now giving attachment a run for its money as the major focus of pop psychology, attachment and “attachment disorders” remain in the lead when people want to have an explanation of development in which one size fits all aspects of childhood and adult personality and behavior.

An example of using attachment to explain everything appeared in the New York Times a few weeks ago, in the business section no less (https://www.nytimes.com/2018/12/19/smarter-living/attachment-style-work-life-balance.html). The author, Elizabeth Grace Saunders, who describes herself as a time management coach, argues that problems at work, like accepting assignments when you shouldn’t, or other irrational decisions, result from “deep subconscious programming known as your ‘attachment style’ ”, which “dictates how you relate to other people, particularly in situations that trigger stress”. She suggests that people can “attach” to the workplace, making their attachment-based views of social relationships apply to their work. (I don’t quite follow this bit, as presumably most people, even those who work from home, experience their work as at least partly a matter of social interactions, so it seems redundant to postulate that a person is “attached” to the work itself, but never mind, this is the least of the problems.)

Saunders proceeds to tell how people can identify their own attachment styles and “take control of how you manage your time). She does not mention the Adult Attachment Interview, a standardized method for assessing attachment styles in adults, which are not necessarily the same styles those individuals showed as toddlers. Neither does she note that attachment is characteristic of a relationship between two people, not necessarily of the individual people themselves. Instead, Saunders turns to self-identified behavior toward other people as the key to “attachment style”. She describes “attachment styles” in the workplace as causing specific problems, and requiring specific solutions.

Saunders equates a fear of upsetting others with an anxious preoccupied attachment style and links this with compulsively checking email and reluctance to set boundaries. She suggests self-talk and asking for peer support as ways to overcome these problems. As a second possible category, she equates dismissiveness of criticism and mistrust of others’ ability, and resulting conflict, with dismissive avoidant attachment (even though the term “dismissive” in this context generally means that the person dismisses concerns about being cared for by others). These people, Saunders says, miss deadlines, work for unnecessarily long hours, and hate to be micromanaged. She suggests the need to “consciously work on your emotional intelligence, including recognizing…that there is value in working harmoniously with others”; apparently Saunders believes that that “deep subconscious programming” can be overcome by conscious decision-making. As a third “work attachment” category, which she calls fearful avoidant attachment, Saunders suggests that some workers may be fearful of threats and lack confidence that they can overcome them, which she apparently considers analogous to a toddler’s snubbing his mother on reunion after a separation. These people, she says, spend their time on social media or reorganizing their desks as an escape from dealing with their assigned tasks. They too need to use positive self-talk and get peer support, according to Saunders. Finally, people who can work effectively and maintain a good work-life balance, who can ask for help or give it, have secure attachment styles (and presumably that’s how you know they have secure attachment styles).

Let me pose a question here. Would it have made the slightest difference to the value of the discussion by this time management coach if she had omitted to mention attachment or attachment styles at all? What if she had said this: If you compulsively check email and have trouble with boundaries, do some positive talk to yourself and ask others to help you with the problem. If you don’t trust others and dismiss criticism too easily, try asking others to manage you  so you can experience this as not so painful, and try to think a lot about how other people think and feel. If you spend your time on social media and organizing your desk, tell yourself positive things about your work and its value and ask other people to support you on this. If you don’t have any of these problems, just keep doing what you’re doing.

Given that these solutions work (and I have no idea whether they do), they are the important part of the article. The focus on attachment is just the spoonful of sugar that may or may not make the medicine go down--  and of course it appeals to the desire we all have to think about the great Me. No doubt talking about attachment in the business section also had a piquancy that helped get this piece published. But the fact remains that attachment is neither a necessary nor a sufficient explanation for problematic workplace behaviors.

I await with interest an article on a trauma-informed approach to poor work habits.


Tuesday, December 11, 2018

Eye Contact and Autism: Questions About a Baby


Over the years, I’ve posted on this blog several comments about whether it’s possible to identify autism in young infants. It’s clear that nobody can do this with babies less than a year old—and it’s especially unlikely that it’s possible in the first 6 months. There have been many queries and comments on this topic, so many that pages have been filled and it has not been possible to post any more, even though I’ve started a new page from scratch several times.

Today I’m going to start again because of a query I received in my email. I think other people may be interested in reading this mother’s questions and my comments, and I hope readers will respond to her if they have something helpful to say about the points that are worrying her.

The mother writes:

I would love to pick your brain about my 5 month old baby who seemed to be developing socially normally up until he turned 3 months. After that his eye contact has gradually decreased and he seems to be getting more and more interested in the world around him. 

My comment: Your baby is still in the process of developing vision and becoming able to use his eyes in coordination. He can also see clearly at greater distances than he did earlier. It’s not surprising that he is interested in all those things to look at that used to be just part of a blurry cloud behind the nearer things that he could see well.

His cooing back to me has also declined though he will occassionally coo to himself or make a couple of sounds to me when he first sees me. He also sometimes says ma. Yesterday and today he also copied me when I said uh oh after he dropped his toy. He also growls in frustration and will look at me angrily as if in plea to pick him up or to stop reading. He understands "up" and "milk" as he'll prepare his body in response. 

My comment: Cooing is an early form of vocalization that helps babies move toward speech. Your baby sounds as if he is beginning the next stage, syllabic babbling, where he creates syllables with a consonant and vowel. Some of these sound like words (“mama”) but the baby does not really connect them with things or people and is just as likely to say “ma” to the cat as to you. What’s really a sign of good development is that you and he are beginning to communicate with sounds and he has already imitated you once. There’s nothing autistic about that. This baby pays attention to people and thinks they are interesting/

He does follow people around the room with his eyes and seems to like looking at people when they are not looking at him. He never looks at me when I hold him. When we move him playfully up in the air he might look for a split second. 

My comment: People looking at him are probably not walking around, and someone walking around provides a lot of interesting things to look at. I doubt that he’s avoiding looking at faces, just choosing to look at more complicated moving things. Babies don’t really gaze into their mother’s face at length, the way sentimental advertising photos seem to show, at this age, although later he will probably look at you while exploring your face with his hands, for instance sticking his fingers up your nose—a scene the ads never show!

He sometimes giggles, occassionally has a laugh and he usually smiles back at me when he first sees me. However I just feel that I am working hard to engage with him. I need to be very animated and fun to get him to look at me for more than a second. Even playing/tickling his feet and toes isnt getting much of a response these days. He will look at me the longest when I am singing and dancing. His attention for books is ok though it used to be better.

My comment: It can feel like a lot of work to engage a baby this young, especially if you are feeling anxious and not having so much fun yourself. Do you think you are looking a bit blank or worried or sad? Babies do tend to look away from that kind of expression. But also, not every baby reacts easily or actively—some don’t show very much whether they are interested in something, and those are just personality differences, not developmental problems at work. As for his attention to books, I  would be surprised if he has actually been paying attention to them at all rather than just listening to your voice and noticing colors and movement. I know everybody is told nowadays to make their baby literate from birth by reading aloud, but in fact talking and social play are the things that babies respond to most, and involving books at an early age is mainly useful to make connections between books and pleasant social times. (Although parents who don’t feel comfortable talking to a baby may find reading aloud to be easier.)  

His motor skills are good and his attention for his toys are great. He does tend to look at the ceilings light fixture and window blinds a lot which worries me.

My comment: He does need to figure out which are the background things that don’t move by themselves and which are the moving things, but in addition these large shapes are interesting to him although not to you. He has a lot to learn about the visual world and concepts like “in front of” and “behind” that seem obvious to adults but did have to be learned even for us.

If it was up to him he would be walked around for the whole day looking at the world. Though at the same time he has never shown separation anxiety. 

My comment: Of course it’s more interesting to move around and see things than just to stay in one place, and he can’t do it by himself, so he would like you to help him do it. (This doesn’t mean you have to!) As for separation anxiety, I would be astonished if he had shown any at his age! At least two or three months will pass before he comes to that point in development, maybe even longer than that.

I am very anxious about him having autism. I'm an OT working with kids on the spectrum and I have been anxious about autism since I was pregnant. I have started seeing a psychologist.  

My comment: I’m glad to hear that you are getting some treatment. I am thinking that even though almost all parents of young infants worry a lot about possible problems, your fears strike me as part of a perinatal mood disorder in which anxiety and sadness make you interpret normal behavior as frightening symptoms. Such disorders can be present at milder or more severe levels, but they can be treated, and for your own sake as well as your baby’s and your husband’s it is best to get help for them.

******************************************************

By the way, I sometimes think that women in the helping professions may have extra difficulties along these lines. They are used to focusing on developmental problems rather than thinking in terms of the many variations of normal development. In a most unfortunate case in South Dakota recently, a psychologist engineered an intentional car crash that fortunately did not succeed in killing her and her 6-month-old baby. Under the influence of a mood disorder, she had convinced herself that her baby had reactive attachment disorder, which would be impossible at that age. I am not suggesting that the mother whose questions are above is in anything like that position, but her unhappy focus on what might be wrong may be worsened by her knowledge of what can go wrong—and she may have seen children with real problems a lot more often than normally developing children.

Friday, December 7, 2018

Peer Review Is Better Than Nothing (But Not Magic)


I recently saw a nice image of a demonstrator with a sign that said: “What do we want? Evidence-based policy. When do we want it? After peer review.”  And, yes, that is what we want—but it doesn’t pay to assume that peer review is the complete answer to understanding whether evidence is reliable.

Plenty of publications are not peer-reviewed. Newspapers and popular magazines are good examples. Articles in these publications may have been requested and paid for by an editor, or chosen by an editor from material submitted by writers. High-quality newspapers and magazines have fact-checkers and run specialized material past knowledgeable people (as well as past their lawyers, who decide whether a charge of defamation will result from publication). Lower-quality journalism may simply use articles because they are sensational and will help sales or because they support an organization’s claims and policies. The same issues apply to Internet materials as to print publications.

Professional journals, however, are supposed to be peer-reviewed, and most of them carry on a front or back page the statement that articles are assessed by peer reviewers. This means that an editor who receives a submitted article will choose two or three people who are thought to be experts in a field (often members of the journal’s editorial board) and will ask them to read and comment on an article, make a recommendation about acceptance or rejection, and list minor or major changes that they think are needed before the article is published. This can be a lot of work and may or may not be done well, depending on the peer reviewers selected. (If the article topic is unusual, it can be hard for an editor to find knowledgeable peer reviewers.)

The idea of peer review is that reviewers are supposed to know the background and previous publications on a topic, but even  though specialists usually have opinions on their specialty, they are expected to be able to take an unbiased approach. The paper is sent to the reviewers without the author’s name on it, but in some specialized fields the reviewers do know who is working on what topic and may be able to guess who wrote the “anonymous” paper. We can hardly expect reviewers to be so pure that they can ignore their own opinions or their guesses about an author’s identity (BTW, authors can sometimes guess reviewers’ names too), but most reviewers do try hard to be objective. The work they do to suggest revisions to a paper helps them do this by making them focus on what would be needed to improve an article.

Peer reviewers are supposed to consider whether an author has paid attention to relevant current literature, whether the design or internal logic of a study supports the conclusion drawn, whether any statistical work was done correctly and whether the number and nature of the participants in an empirical study was sufficient for the purpose, and whether there are ethical issues to be discussed. Reviewers also need to pay attention to the way an article is written and whether it is clear enough that readers will understand it. The reviews that go to the author need to touch on these matters and often include specific details.


Once an author has received a set of peer reviews from an editor, it’s his or her job to revise the paper to meet the recommendations of the reviewers and respond to their critiques—or argue why those changes would be inappropriate. The revised paper is then returned to the editor with a list of reviewers’ comments and how the author has responded to them, and the editor may decide on his or her own to accept or reject the paper as it stands, or may return it to the reviewers for further decisions. (This is one of the reasons it takes a long time for an article to get into print.)

As you can see, this is a very well-intentioned process that can help keep weak or even fraudulent material out of professional journals--- when everything goes according to plan. It’s a better approach than anything else we have at the moment and certainly more desirable than letting every submitted article be published or leaving all decisions to the preferences of a few editors, who can’t possibly be knowledgeable about every area of their discipline. But at the same time, look at the potential flaws that mean that there is no magic in peer review. Mistakes may be made in choosing reviewers, or reviewers with a particular bias may be chosen by some journal editors. Being human, reviewers can also make mistakes of all kinds, fail to pay attention to every point they should consider, or take on too much work so they do not have time to do a good job. They may also fail to completely understand the goals of a journal--  for example, another reviewer and I once bent over backward to make suggestions about how an author should revise a paper with a questionable topic, only to have the editor reject the paper out of hand because of the subject matter and the way it was handled.

Because peer review is a human process, we should never assume that a paper that has been published even after excellent peer review is necessarily True with a capital T. The burden remains with the reader to consider the weight that should be given to a publication. It’s very helpful to know that a few other people have critiqued a paper, and certainly reviewers’ comments can help an author improve a paper a great deal. But there’s no magic truth in peer review – it’s just better than the alternative.

Another thing about this: sometimes editors invite an author to submit a paper. Those invited papers are not peer reviewed, but the authors are free to say that their paper was published in a peer-reviewed journal. This is the case for an article by Forrest Lien currently posted on line for Child and Adolescent Social Work Journal. This invited paper is basically a puff piece and would not have been accepted if it had been submitted in the usual way, but it was invited in order to give Lien a chance to respond to some criticism of his methods. Unfortunately it also gives him a chance to say that there is a peer-reviewed publication recommending Lien’s approach.

Finally, there are presently quite a lot of “predatory journals”. These are outfits that invite submissions but conceal the fact that they are going to charge for publication, refuse to let an author withdraw a paper, and put a collection agency to work if the author does not pay up. Obviously the papers that end up in those publications are not peer-reviewed no matter what the journals say. (I get half a dozen of these journals contacting me every day, and I’m sure this is also true for anyone who has published in a real professional journal.)

The moral of our story is Caveat Lector—let the reader beware! Peer review is good, but the responsibility for evaluating publications remains in our own hands.






Thursday, December 6, 2018

Closing Argument in a Child Custody Case Involving Accusations of Parental Alienation


 The following closing argument was submitted by minors' counsel John Myers in a California child custody case that involved allegations of parental alienation efforts by the mother as the cause of children's reluctance for contact with their father. Craig Childress was called as an expert witness by the father's counsel, and I was an expert witness called by the minors' counsel.

There is further evidence to be brought in this matter and no decision is available as of this writing.




SUPERIOR COURT OF CALIFORNIA

IN AND FOR THE COUNTY OF YOLO



Lisa Sahar,
                     Petitioner,

vs.

David Sahar,
                       Respondent.
 
Case No. FL15-1669


S___ and R___’s Closing Argument

            Come now S___ and R___ Sahar, through their attorney, and respectfully file this Closing Argument.
I
The Bottom Line

            The loadstar for the Court is the children’s best interest. The evidence at trial makes six things clear. First, S___ and R___ are extraordinarily bright teenagers, capable of great academic and personal achievement. Second, in their mother’s care, S___ and R___ are thriving. Third, S___ and R___ want to continue living with their mother. Fourth, S___ and

R___ are estranged from their father, Dr. Sahar. Fifth, if a way can be found to repair the rift between the children and their dad, it is in S___ and R___’s best interest—not to mention in Dr. Sahar’s interest—to do so. Sixth, removing the children from their mother—as Dr. Childress and Dr. Sahar recommend—is a path to destruction, not repair. Wrenching the children away from their mother could very well crush S___, and do equal harm to R___.

            R___ and S___ respectfully ask this Court for the following orders: (1) Joint legal and physical custody. (2) R___ and S___ continue to live with mother. (3) A “cooling off” period of six months, during which they are not ordered into therapy or ordered to spend time with Dr. Sahar.[1] S___ testified eloquently that she wants the court process to end. She wants to be a normal teenager. It will be useful for the Court to encourage the children to communicate with their dad during the cooling off period, but to refrain from ordering them to do so. (4) A review hearing in six months to see how things are going.

II
S___ and R___’s Kelly/Frye Motion


            On April 4, 2018, S___ and R___ filed an RFO requesting a Kelly/Frye hearing regarding proposed expert testimony from Dr. Craig Childress, father’s expert. By Minute Order dated June 4, 2018, the Honorable Kathleen White, “granted” the RFO “in part,” writing that the “Court will hold a 402(b) hearing as to Dr. Childress as part of the trial.” During the trial, the Court held the requested hearing.


            A. Summary of Kelly/Frye Argument

            Dr. Childress has a theory of parental alienation—he calls it a model.[2] He applied his theory/model to assess and diagnose S___ and R___’s mother with “pathogenic parenting.” Based on his theory-driven assessment and diagnosis, Dr. Childress rendered a custody recommendation.[3] Dr. Childress’s theory/model is not generally accepted as reliable in the psychological community. Because his theory/model is not reliable, his diagnosis and custody recommendation are unreliable, and should not be followed by the Court.

            B. Dr. Childress’s Theory of Attachment-Based Parental Alienation

            In 2015, Dr. Childress self-published[4] a non-peer reviewed book titled An Attachment-Based Model of Parental Alienation: Foundations.[5] In his book, Childress wrote that attachment-based parental alienation “is a valid clinical phenomenon that is manifested in an identifiable
pattern of symptoms.”[6] Childress theorizes that attachment-based parental alienation is caused by “distortions to the child’s attachment system” that, according to Childress, can “only” be caused

by “pathogenic parenting.”[7] Childress claims that if “three diagnostic indicators for attachment-based parental alienation” are present in children, he—Childress—can definitively diagnose attachment-based parental alienation.[8] According to Childress, attachment-based parental alienation is either present or absent. Childress sees no shades of gray, no degrees of alienation. In Childress’s model, attachment-based parental alienation is all or nothing.[9]

            Dr. Childress’s book, Foundations, provides a comprehensive description of, and explanation for, parental alienation. The good doctor calls his approach a “model.” He could equally have called it a theory. It is both. Dr. Jean Mercer, a retired professor of psychology, testified for S___ and R___. Dr. Mercer defined a “theory” as a “framework that someone has created to try to pull together things that they can observe in the world . . . .”[10] The dictionary definition is similar: A supposition or system of ideas intended to explain something. Thus, Einstein posited the theory of relativity. Darwin’s is the theory of evolution. Childress contributes the theory of Attachment-Based Parental Alienation.

            Dr. Childress’s theory/model of parental alienation is new to psychological science. In his book, Dr. Childress seemed comfortable, even proud, that his model is “new.”[11] Of course, if Childress’s book is right—his model is new—then his model is a good candidate for analysis

under Kelly/Frye. At trial, Dr. Childress seems to have understood this because, when he was asked on cross-examination whether his model is new, Dr. Childress testified, “No.”[12] Indeed, to avoid subjecting his model to the microscope of Kelly/Fry, Dr. Childress went so far as to testify there is no such thing as attachment-based parental alienation.[13] This is a remarkable statement from the man who titled his book—“Attachment-Based Parental Alienation,” and the man who wrote that attachment-based parental alienation is a valid clinical phenomenon. In a further effort to distance his model from Kelly/Frye, Dr. Childress testified on direct examination, “I have no theory. There is no theory of Dr. Childress.”[14]  

            Dr. Childress applied his model/theory to S___ and R___. In his “Treatment-Focused Assessment” dated March 12, 2018, Dr. Childress wrote, “S___ and R___ both display the three symptom indicators of pathogenic parenting associated with an attachment-based model of ‘parental alienation.’”[15] To support his opinion, Childress cited his book, Foundations.

            It is respectfully submitted that Dr. Childress can’t have his cake and eat it too. He can’t have his theory of alienation, publish a book on it; apply it to S___ and R___, and then run away from his own invention to escape Kelly/Frye.



            At the heart of Childress’s theory/model is the “narcissistic/(borderline) parent”[16] who alienates the children. A fundamental precept of Childress’s theory is that developmental trauma during early childhood—specifically disorganized attachment—leads to narcissism/borderline symptoms in the alienating parent.[17] Throughout his book, Childress asserts that disorganized attachment in early childhood causes narcissistic/borderline symptoms in adulthood. Directing the Court’s attention to Minors’ Exhibit 201, the Exhibit reproduces nine quotes from Childress’s book, each of which, in varying words, postulates a causal relationship between disorganized attachment and narcissism/borderline personality disorder in adulthood. Thus, Childress writes:

[N]arcissistic/(borderline) personality structure that has its origins in early attachment trauma from the childhood of the parent which is influencing . . . .”[18]

The childhood attachment trauma (i.e., a disorganized attachment) creates the narcissistic and borderline personality structures . . . .”[19]

Both the narcissistic and borderline personalities represent the coalesced product of disorganized attachment patterns from childhood.[20]


Narcissistic and borderline personality dynamics represent the coalesced product of underlying patterns of attachment expectations. The particular type of attachment pattern that results in the formation of a narcissistic/(borderline) personality organization is called a disorganized attachment.[21]



[D]isorganized attachment in early childhood (which in turn, leads to the formation of narcissistic and borderline personality traits during later adolescence and early adulthood) . . . .[22]


            If Dr. Childress is wrong about a causal relationship between disorganized attachment in early childhood, and narcissistic/borderline characteristics in adulthood, then one of the main pillars of his theory/model collapses. As the testimony of Dr. Mercer shows, Dr. Childress is wrong, although Childress does not think so. The Court asked, “Dr. Childress, you mentioned there’s literature liking disorganized attachment to borderline personality. How tight is the linkage?”[23] Childress answered, “Very tight.”[24]

            C. Dr. Mercer’s Testimony

            The Court qualified Dr. Jean Mercer as an expert on attachment. Dr. Mercer has written on and studied attachment for decades. Her testimony indicated deep familiarity with the theory of attachment and with the attachment literature.

            As discussed in subsection B, supra, a fundamental tenant of Childress’s Attachment-Based Parental Alienation is his assertion that disorganized attachment causes narcissism and borderline personality disorder in adults. Dr. Mercer’s testimony refutes Childress’s assertion.


Dr. Mercer testified that it is not possible to “predict mental illness in adulthood” simply because a toddler demonstrates disorganized attachment in the Strange Situation.[25] Dr. Mercer explained:

A: The assumption that is too often made is that if you see disorganized attachment behavior in a toddler that we can predict with, you know, considerable accuracy that there will be mental illness developing in later life.

Q: Can we not make that prediction?

A: No, we cannot.[26]


            Referring to articles from the peer reviewed professional literature—articles on which Dr. Mercer relied for the opinions she offered in court—Dr. Mercer explained that disorganized attachment is a risk factor for difficulties later in life, including mental illness, but that science cannot draw a direct causal connection between disorganized attachment and narcissism, borderline, or any other mental illness.[27] Dr. Childress is simply wrong to assert the contrary.  

            Dr. Mercer offered five opinions, to a reasonable degree of scientific certainty. First, Dr. Mercer opined that mental health professionals cannot accurately determine what type of attachment an adult had as a toddler, by interviewing the adult.[28] Father presented no evidence to contradict Dr. Mercer’s opinion. Dr. Childress, in his reports and his testimony, asserted time and again that Lisa Sahar demonstrated disorganized attachment. On cross-examination, Dr.

Childress was asked, “Isn’t it true, Doctor, that you have no way whatsoever of knowing what type of attachment Lisa Sahar had during her infancy.” Childress responded, “That’s not exactly correct. There’s another instrument called the adult attachment interview where you can do an interview with an adult . . . .” But the doctor admitted that he did not employ the adult attachment interview with Mrs. Sahar. Further, Dr. Childress admitted he had no idea whether Mrs. Sahar experienced the Strange Situation when she was little, and it is the Strange Situation that is the gold standard for characterizing attachment.[29]  In the final analysis, Dr. Mercer’s opinion that it is not possible to determine attachment style by interviewing an adult is uncontradicted.

            Second, Dr. Mercer opined that it is not scientifically possible to draw a direct, causal link between disorganized attachment in a toddler and narcissistic personality disorder or borderline personality disorder in an adult.[30] Dr. Mercer opined that Dr. Childress, in his book Foundations, asserts that it is possible to draw a direct causal connection between disorganized attachment in early childhood and the development of narcissistic and borderline personality traits. It is interesting to note that although Dr. Childress’s book repeatedly asserts a causal connection between disorganized attachment and narcissistic/borderline (see Minors’ Exhibit
201), once his theory was attacked by Dr. Mercer, Dr. Childress ran the other direction, testifying that his book does not presuppose a causal connection.[31] The Court will determine


which version of Dr. Childress’s words to believe, and whether Dr. Mercer or Dr. Childress has the science on their side.

            Third, Dr. Mercer opined that the community of mental health professionals does not generally accept Dr. Childress’s attachment-based parental alienation as a reliable and valid theory.[32] Dr. Mercer explained:

A: Well, first of all, I don’t think that most psychologists have ever heard of this [i.e., Dr. Childress’s work], and second, if they have heard of it and they’ve read it and they know anything about how attachment functions it couldn’t possibly accept this as legitimate, you know, we’ve got decades of theory and research about this and none of [Childress’s work] fits into it or is congruent with it.[33]


            Dr. Sahar presented no evidence, apart from the testimony of the creator of attachment-based parental alienation, to refute Dr. Mercer’s opinion. Indeed, Dr. Sahar’s strategy to deal with Dr. Mercer’s opinion that the professional community does not generally accept attachment-based parental alienation appears to have been for Dr. Childress to testify he has no theory, and that there is no such thing as attachment-based parental alienation![34] During cross-examination,
Dr. Childress was asked, “So your book has nothing to do with your testimony? He answered, “That’s correct.”[35] Apart from Dr. Childress’s rather transparent effort to avoid dealing with the

fact that the scientific community does not accept his theory/model, Dr. Sahar presented no evidence to refute Dr. Mercer’s opinion. Her opinion is, therefore, uncontradicted.   

            Fourth, Dr. Mercer opined that the community of mental health professionals does not generally accept Dr. Childress’s attached-based parental alienation model as a reliable diagnostic tool.[36] Dr. Sahar presented no contradictory evidence, apart from the contradictory testimony of Dr. Childress.

            Fifth, Dr. Mercer offered the opinion that the community of mental health professionals does not generally accept Dr. Childress’s recommended treatments, including Childress’s so-called protective separation from the allegedly abusive parent, or the High Roads program operated by Childress’s collaborator, Dorcy Pruter.[37] Dr. Childress himself admitted there is no empirical evidence, published in the peer reviewed literature, that Pruter’s program works.[38] Neither Dr. Sahar nor Dr. Childress provided evidence for the efficacy of so-called protective separation. Thus, Dr. Mercer’s testimony on this point is uncontraicted.

            D. Conclusion Regarding Kelly/Frye

                It is respectfully submitted the Court should credit Dr. Mercer’s testimony. With her testimony credited, the Court should grant S___ and R___’s Kelly/Frye motion, and exclude from consideration the testimony offered by Dr. Childress. It is junk science, and worse than

that, it is junk science that poses a clear danger to the mental stability and happiness of these two highly intelligent, high functioning teenagers.

III
Even if the Court Denies the Kelly/Frye Motion,
the Court Should Disregard the Childress Recommendation


            S___ and R___ argue that Dr. Childress’s model of parental alienation is dangerous junk science that has no place in deciding the children’s fate. However, if the Court determines that Kelly/Frye does not exclude Childress’s work, S___ and R___ respectfully urge the Court to give Childress’s “assessment” and testimony no credit.
           
            A. “Assessment” in Name Only


            Dr. Childress did not perform an assessment to determine whether the children were experiencing attachment-related parental alienation. Before he began his “assessment,” Dr. Childress already had an answer to that question: Yes. His only assignment was to discover the culprit.

            It is clear beyond cavil that Dr. Childress’s mind was made up before the assessment began. During his direct examination, Childress testified, “So the first thing I had to organize was what’s the referral question the assessment is designed to answer? So the referral question I’m answering is which parent is causing the child’s attached-related pathology . . . .”[39]  On

cross-examination, Dr. Childress was asked: “Q: So, when you came into this case, before you started your assessment, you had already concluded that there was pathological – pathogenic parenting, hadn’t you?”  “A: That’s the only thing that causes attachment pathology.”  “Q: So the answer would be yes, you had concluded there was pathogenic parenting?”  “A: Yes.”[40]  When asked, “You were hired by father to determine who is the source of pathogenic parenting; right?” Childress answered, “Correct.”[41]

            Before Childress’s “assessment” began, the man who hired him, Dr. Sahar, pointed the accusatory finger at Mrs. Sahar. Dr. Childress obliged Dr. Sahar by confirming father’s opinion.

            B. Dr. Childress’s Assessment is Bush League Compared to Dr. Nelson’s


            In May, 2016, Dr. Nelson conducted a thorough child custody evaluation.[42] In June, 2017, he updated his evaluation.[43] Dr. Nelson’s trial testimony was clear and persuasive. In sum,
the doctor found fault with both parents.[44] Three things stand out. First, after administering psychological tests, contacting multiple collateral sources of information, and spending considerable time interviewing her, Dr. Nelson found mother suffers no significant mental illness

or dysfunction.[45] Dr. Nelson detected no signs of narcissistic personality disorder or borderline personality disorder. Second, Dr. Sahar became uncooperative with Dr. Nelson when it looked as though Dr. Nelson was not falling in line with Dr. Sahar’s view of the case.[46] Third, Dr. Nelson performed a thorough assessment of the children. In his first report, the children were suffering.[47] By the time of the update, S___ and R___ were doing much better.[48] Is it a coincidence that the children’s improved functioning occurred while in mother’s care?

            Dr. Childress’s “assessment” cannot hold a candle to Dr. Nelson’s thorough 2016 and 2017 evaluations of the entire family. Childress conducted no psychological testing.[49] He contacted no collateral sources.[50] He spent much less time with the family, and, importantly, he did not bother to evaluate the children with their mother.[51] On cross-examination, the question
was asked: “You reached your recommendations without ever seeing the children interact with their mother; isn’t that right?” Childress answered, “That’s correct.”[52]



            Of course, Dr. Childress does not think much of Dr. Nelson, or of custody evaluators in general. On cross-examination, Childress testified as follows:

Q: Of course, you are not a big fan of child custody evaluators like Dr. Nelson, are you?


A: I don’t think the process is reliable or valid.[53]

*   *   *

Q: You assert – you asserted in your PowerPoints that child custody evaluators like Dr. Nelson, quote, simply make it up, end quote?

A: That’s what I said.

Q: In your report dated August 16th of 2018, you wrote, “Dr. Nelson reached his conclusions and made his recommendations on faulty constructs that are poorly defined in professional psychology.” Is that your statement?

A: That is my statement.[54]


           
            According to Dr. Childress, child custody evaluators like Dr. Nelson have nothing to offer. But that’s not all: Dr. Childress testified there is no such thing as reunification therapy.[55]
According to Dr. Childress only clinical psychologists, like him, have anything useful to contribute. The man’s egotism is astonishing. S___ and R___ respectfully ask the Court to give weight to Dr. Nelson’s evaluations, and to give Dr. Childress’s assessment the respect it deserves: None.

            C. Dr. Childress’s Tactics with the Children During the Assessment were Unprofessional

            During his “assessment” meeting with the children, Dr. Childress called the children cruel. Dr. Childress admitted, “I said what they were doing potentially is cruel.”[56] During his meeting with the children, he accused them of lacking empathy for their father.[57]

            During her testimony, S___ recalled Dr. Childress accused the children of bullying their father.[58] S___ testified:

A: . . . [A]nd he was going on and on and he was rolling around in his chair and making crazy expressions also like a show almost and he was saying you guys are bullying the poor autistic kid [their father], he kept doing stuff like that and then he said you can’t possibly not like your father, it’s not possible, you know, you guys are like animals, when a hamster is being attacked, a baby hamster is being attacked by a snake, you have to go back, they go to their parent or something like that for them to be protected, and I let him know the difference is animals go by instincts, humans, we have experiences that kind of transform what we do . . . .”[59]


 *  * *

A: . . . Honestly, it was so traumatic I just kind of blocked it out and, you know, I don’t really mind that, and yeah. He would say like about my mom was manipulating us and stuff like that.

Q: Dr. Childress told you this?

A: Yeah  . . . .[60]

           
            D. Dr. Childress Violated Ethical Guidelines Applicable to His Assessment

            Dr. Childress is a member of the American Psychological Association (APA).[61] The APA Specialty Guidelines for Forensic Psychology are in evidence (Minors’ 211). The Guidelines apply to Dr. Childress because, in performing his assessment and testifying, the doctor was practicing forensic psychology. The forensic Guidelines state:

           For the purposes of these Guidelines, forensic psychology refers to professional practice by any psychologist working within any subdiscipline of psychology (e.g., clinical, developmental, social cognitive) when applying the scientific, technical, or specialized knowledge of psychology to the law to assist in addressing legal, contractual, and administrative matters. . . . These Guidelines apply in all matters in which psychologists provide expertise to judicial . . . systems . . . .[62]



            Dr. Childress admitted during cross-examination that this is a custody case.[63] In the context of custody litigation, Dr. Childress conducted an assessment for use in court. He testified. It is clear beyond peradventure that Dr. Childress’s involvement constitutes the practice

of forensic psychology. Indeed, although he was more than a little reluctant to do so, Dr. Childress admitted he was engaged in forensic psychology. On cross-examination, the following exchange occurred:

Q: Do you agree that you are practicing as a forensic psychologist in this matter?

A: I agree that that’s what the guidelines define me as doing.

Q: And these are the guidelines promulgated by the American Psychological Association; is that right?

A: As guidelines, not as mandatory.

Q: I understand that. So it’s your testimony, then, that these guidelines do not apply to your performance in this case?

A: I am just saying that the guidelines apply, but I am a clinical psychologist.

Q: Did I understand you correctly, you are saying the guidelines apply?

A: Yes.[64]


            During his assessment, Dr. Childress violated APA forensic psychology Guidelines 4.02 and 4.02.01, dealing with “Multiple Relationships.” The Guidelines provide, in relevant part:


Guideline 4.02: Multiple Relationships

A multiple relationship occurs when a forensic practitioner is in a professional role with a person and, at the same time or at a subsequent time, is in a different role with the same person . . . .



Guideline 4.02.01: Therapeutic-Forensic Role Conflicts

Providing forensic and therapeutic psychological services to the same individual or closely related individuals involves multiple relationships and may impair objectivity and/or cause exploitation or other harm.


            During Dr. Childress’s direct testimony, he enthusiastically admitted he mixed forensic and clinical roles with the children. Dr. Childress testified:

I begin to actually treat the concerns that were raised by the children in the third session.[65]

So I’m actually starting to do treatment now . . . .[66]


            On cross-examination, Dr. Childress was confronted with the APA guidelines on multiple relations, and he tried mightily, but without success, to backtrack on his admissions he mixed clinical and forensic roles.[67]

Dr. Childress violated the ethical guidelines of the American Psychological Association, to which he belongs. Is his violation relevant to this case? Yes. As the Guidelines state, mixing forensic with clinical roles can “impair objectivity and/or cause exploitation or other harm.” It is respectfully submitted that Dr. Childress’s mixing of roles, combined with his dubious

psychological theories, and his abusive tactics with the children, caused the children unnecessary stress.

            E. According to Drs. Childress and Sahar, Mrs. Sahar is 100% to Blame for   Everything


            More often than not in family law, there is enough blame to go around. In this case, Mrs. Sahar’s testimony indicates she understands she played a role. Dr. Nelson assigned blame to  both parents. Dr. Childress, however, was unequivocal. According to Childress, father is a “normal range” parent who is the completely innocent victim of mother’s pathogenic parenting. Father did nothing wrong. Mother, by contrast, did everything wrong. Mother is 100% to blame. Childress testified, inter alia:

[T]he children’s attachment bonding problems towards their father are being created by the mother’s distorted parenting practices . . . .[68]

[I]t’s the mother who is influencing the children and their perceptions, as well as the false belief system . . . .[69]

It is the mother, in my clinical opinion, who has these beliefs and attitudes toward the ex-spouse, the father, and that S___ is acquiring these attitudes
toward her father form her mother who is the source origin for these attitudes . . . .[70]


[T]his is the mother’s creation . . . .[71]

So [R___ is] triangulated into spousal conflict by his mother to be used as a weapon against his father . . . .[72]



            Dr. Childress’s belief that everything is mother’s fault is reflected in his “Treatment-Focused Assessment,” dated March 12, 2018, and his follow up report dated August 16, 2018.[73] In his March report, Childress wrote, “[I]t is the mother who is the actual source for these feelings toward the father.”[74] Elsewhere in the March report, Childress remarked, “[T]here are no issues of clinical concern regarding the father’s parenting.”[75] Mother, on the other hand, “is creating an emotional cutoff in the children’s symptom display . . . .”[76]  Childress wrote, Mother “appears to say whatever she deems to be the most helpful in achieving her desires of the moment, regardless of the actual truth or accuracy of these statements.”[77] In his August, 2018 update, Childress continued his drumbeat of criticism of mother, writing, “The children’s symptoms are not consistent with the father being the causal source, and instead, the children’s symptom pattern is entirely consistent with the mother’s parenting being the causal origin of the children’s attachment rejection toward their father.”[78]




            Childress’s criticism is so one-sided, so relentless that it lacks credibility. Rather than seeming like the insights of a neutral professional, Childress’s diatribe has the flavor of a hired gun who says what he’s paid to say: Dad is great, Mom is terrible, the kids are delusional.

            Dr. Sahar is a surgeon and a professor of medicine. He is a very intelligent man. It was surprising and disheartening to hear him testify that he accepts no responsibility for the situation
before the Court. It was even more surprising, depressing, and, frankly shocking, to hear Dr. Sahar agree that the children should be removed altogether from their mother’s care. Dr. Sahar has swallowed the Childress view hook, line, and sinker. He drank the Kool Aid, and in doing so, he lost sight of his children’s best interests.


            F. Everybody’s Wrong But Me

           

            Dr. Childress seems quite sure he’s right. He seems equally sure the other professionals involved in the case—with the exception of Dorcey Pruter, who, with her high school diploma (no disrespect intended) is difficult to characterize as professional—are wrong.

            Dr. Childress’s contempt for Professor Mercer is palpable. Childress testified that Dr. Mercer, “[D]oes not understand the established knowledge of professional psychology.”[79] He opined, “[S]he’s not an expert.”[80] In a Facebook post on the day Dr. Mercer testified, Dr.


Childress called Dr. Mercer a “pathogen.”[81] Dr. Childress Facebooked, “We’re going to just swat your little monkey behind right out of the air.”[82] Not very professional Dr. Childress.

            Dr. Childress’s low opinion of Dr. Nelson is discussed elsewhere. In Childress’s “Comprehensive Report” dated August 8, 2018, Childress wrote, “Dr. Nelson reached his conclusions and made his recommendations on faulty constructs that are poorly defined in professional psychology. In the professional opinion of Dr. Childress upon review of the clinical information contained in the report of Dr. Nelson, he identified the broad aspects of the pathology but misinterpreted the meaning of the symptom pattern. This led to conclusions that were faulty and recommendations that were flawed.”[83]

            Dr. Childress’s disdain for everyone but himself extends to therapists Stephanie Stilley and Mimi Fade, of whom Childress wrote, “While the treatment focus of Ms. Stilley and Ms. Fade is understandable and laudable, it is not the proper focus of therapy.”[84]

            After demolishing all the other professionals, the only one left standing is Childress. He is the only one whose viewpoint is worth listening to. He alone sees the truth. With all the respect due Dr. Childress, poppycock.


            G. Conclusion Regarding Dr. Childress’s Assessment and Recommendation

            S___ and R___ respectfully argue that the Court should disregard entirely Dr. Childress’s assessment and his recommendations. They are not worth the paper they are written on.


IV
S___ and R___’s Wishes


            S___ and R___ testified, and made their wishes clear. S___ was asked, “Do you like living at your mom’s house with your mom?” She answered, “Yeah, I do.”[85]  S___ was asked to express her feelings to the Court. She said: “I would not want to see him [father] at this point. The fact that we’re in trial right now and this situation I’m really upset and angry with him. . . . I just feel like everything in our family involves court and just evidence and just lies.”[86]

            R___ was asked, “R___, I want you to tell the judge right now today about spending time with your dad?” He answered, “I don’t like spending time with him at all for reasons that, sorry, I just have to think this is kind of nervous. . . . He mentally hurt me and now I always feel weak and he’s called me names, swore at me, threatened to throw me out on the street just because I didn’t want to eat something. Isolated me from my mom . . . .”[87] R___ described what life is like


with his mother: “It’s nice. It’s a nice setting. I have a room. I am close to my family, we talk a lot, its peaceful, it’s not chaotic. I mean, I would say it’s a nice home.”[88] 

            Both of these highly intelligent, high functioning, college-bound teenagers had much more to say, but the Court heard their testimony, and will judge for itself. The long and short of it is, the children want to live with their mother, in whose care they are thriving. They don’t want
to see their father, which is very sad. Hopefully, with time, and, perhaps, further counseling, a rapprochement will be achieved. Forcing it down their throats, as recommended by Dr. Childress, and endorsed by Dr. Sahar, is not the answer.

V
Conclusion


            S___ and R___ Sahar respectfully ask the Court to order the relief outlined at the beginning of this argument. The kids are doing well. It is in their best interest to keep the current custody arrangement in place.

                                                                                    Respectfully submitted,

Date: Nov.16, 2018                                        _____________________________
                                                                        John E.B. Myers, Minors’ Counsel




Proof of Service


            I hereby certify, under oath, subject to penalty of perjury, under the law of the State of California, that I am over the age of 18, and not a party to this action. On November 16, 2018, I served S___ and R___’s Closing Argument on the parties, by first class mail, and email, as follows:

            Respondent, by service upon his attorney, Wazhma Mojaddidi, 3400 Cottage Way, Suite E, Sacramento, CA 95825, email: wazhma@mojaddidilaw.com

            Petitioner, by service upon her attorney, Jeffrey Posner, 3425 American River Drive, Sacramento, CA 95864, email: jeff@woplaw.com


Date: 11/16/18                                                            ___________________________
                                                                                    John E.B. Myers



[1] The children are seeing counselors, and this can continue as needed, without orders from the Court.

[2] In his book titled An Attachment-Based Model of Parental Alienation: Foundations (2015), Childress writes, “In the descriptions to follow, an attachment-based model for the construct of  ‘parental alienation’ will be elaborated.” (p. 8). See Minors’ Exhibit 202.

[3]  During his testimony, Dr. Childress tried, without success, to argue he did not make a custody recommendation. On cross-examination, Childress was asked, “And you are offering recommendations concerning custody and visitation, aren’t you?” He answered, “No.” (Childress’s testimony, p. 96, lines 6-12). Later, Childress was asked, “You recommended that they [the children] be removed from the mother for a period of time.” He answered, “Yes.” “That’s a custody recommendation, isn’t it?” He answered, “No.” (Childress’s testimony, p. 100, lines 14-18).


[4] See Dr. Childress’s testimony, p. 18, lines 12-13: Q: So this is self-published? A: Yes.”

[5] Emphasis added. See Minors’ Exhibit 202.


[6] Foundations at 6.

[7] Id. at 7.

[8] Id. at 11.

[9] Id. at 11.

[10]  Mercer’s testimony, p. 14, lines 20-21.
 
[11] Foundations at 5.

[12] Dr. Childress’s testimony, p. 171, line 4.

[13]  Dr. Childress’s testimony, p. 102, lines 15-18.

[14]  Id. at 23, line 18. See also, Childress’s testimony, at p. 122, line 4, where Childress testified, “I don’t have a theory.”

[15] Childress Report, p. 1.  Respondent’s Exhibit A.

[16] Childress Testimony at 8.

[17] Id. at 9.

[18] Id. at 17 (emphasis added).

[19] Id. at 19 (emphasis added).

[20] Id. at 39 (emphasis added).

[21] Id. at 48 (emphasis added).

[22] Id. at 50 (emphasis added).

[23] Dr. Childress’s direct examination, p. 29, line 25 to 30, line 2.

[24] Id. at 30, line 3.

[25] Dr. Mercer’s testimony, p. 37, lines14-17.

[26]  Dr. Mercer’s testimony, at p. 38, lines 1-7.

[27]  See Dr. Mercer’s testimony at  p. 58, lines 23-25, where the doctor stated: “[D]isorganized attachment is one of the many risk factors that help to determine whether someone will be mentally ill in adult hood.”

[28]  Dr. Mercer’s testimony, p. 59, lines 23-25 and p. 60, lines 1-3.

[29]  Dr. Childress’s testimony, p. 145, lines 11-25 and p. 146, lines 1-2. See also, Dr. Childress’s testimony at p. 147, lines 1-12.

[30]  Dr. Mercer’s testimony, p. 61, lines 2-13.

[31] See Dr. Childress’s testimony, p. 170, lines 19-23.

[32]  Dr. Mercer’s testimony, p. 69, lines 7-13.

[33]  Dr. Mercer’s testimony, p. 69, at lines 7-22.

[34]  See Dr. Childress’s testimony, p. 172, at line 7, “There is no such thing as ABPA.” And p. 173, lines 6, “There is no such thing as my approach.”

[35]  Dr. Childress’s testimony, p. 168, lines3-5.

[36]  Dr. Mercer’s testimony, p. 70, lines 10-15.

[37]  Dr. Mercer’s testimony, p. 71, lines 11-25 and p. 72, lines 1-16.

[38] Dr. Childress’s testimony, p. 165, lines 19-22.

[39] Childress’s testimony, at p. 33, lines 9-14.

[40] Childress’s testimony, at p. 114, lines 5-13.

[41]  Dr. Childress’s testimony, p. 119, lines 16-17.

[42]  Petitioner’s Exhibit 16.

[43]  Petitioner’s Exhibit 17.

[44]  Dr. Nelson’s 2016 Report at p. 49 (“Lisa and David both have strengths and weaknesses in terms of their parenting skills.”). See also, Dr. Nelson’s 2017 Report Update, at p. 18 (“Both parents contribute to the continuing conflicts, although David’s contribution may be someone more significant.”).

[45]  Dr. Nelson’s 2016 Report at p. 18 (“no clinical psychopathology indicated”).

[46]  Dr. Nelson’s 2017 Update at pp. 19-20.
 
[47]  Dr.. Nelson’s 2910 Report at pp. 18-25.

[48]  Dr. Nelson’s 2017 Report Update, pp. 18-19 (“S___ has made significant progress since the last time I met with her in March 2016. S___ has been attending school consistently and just completed ninth grade with a 4.0 grade point average. She has been doing much better socially . . . . R___ also seems to have made much progress . . . . R___ is now functioning remarkably better.”).

[49]  Dr. Childress’s testimony, p. 105, lines 8-13.

[50]  Dr. Childress’s testimony, p. 105, lines 23-25 and p. 106, lines 1- 13.

[51]  Dr. Childress’s testimony, p. 105, lines 20-22.

[52]  Dr. Childress’s testimony, p. 108, lines 1-4.

[53]  Dr. Childress’s testimony, p. 120, lines 5-8.

[54]  Dr. Childress’s testimony, p. 120, line 25 and p. 121, lines 1-9.

[55]  Dr. Childress’s testimony, p. 123, lines 2-6. In contrast to Dr. Childress, Dr. Mercer opined that reunification therapy is a legitimate area of practice, generally accepted among psychologists. Dr. Mercer’s testimony, p. 80, lines 19-24.

[56]  Dr. Childress’s testimony, p. 131, lines 11-14 and p. 132, lines 1-4.

[57]  Dr. Childress’s testimony, p. 134, lines 4-11.

[58]  S___’s testimony, p. 24, lines 19-20.

[59]  S___’s testimony, p. 25, lines 1-13.

[60]  S___’s testimony, p. 26, lines 2-7.

[61] See Childress’s testimony, p. 16, lines 19-20. “I am a member of the American Psychological Association.” See also, p. 92, lines 22-24.

[62]  Minors’ Exhibit 211. American Psychological Association, Specialty Guidelines for Forensic Psychology, 68 American Psychologist 7-17, at p. 7 (2013).

[63]  Dr. Childress’s testimony, p. 92, lines1-2 and lines 12-18.

[64]  Dr. Childress’s testimony, p. 94, lines 14-25 and p. 95, lines 1-4.

[65]  Dr. Childress’s testimony, p. 34, lines 23-24.

[66]  Dr. Childress’s testimony, p. 43, lines 14-15.

[67]  Dr. Childress’s testimony, p. 123, lines, 18-25 and  pp. 124-128, all lines.
               
                Dr. Childress went so far as to testify that mixing clinical roles and forensic roles is not an ethical violation, a point that is clearly contradicted by the APA guidelines. See Dr. Childress’s testimony at p. 129, lines 5-8.

[68]  Dr. Childress’s direct testimony, p. 40, lines 17-19.

[69] Id. p. 48, lines 18-19.

[70] Id. p. 59, line 25 to p. 60, lines 1-5.

[71] Id. p. 65, lines 12-13.

[72]  Id. p. 73, line 9-10.

[73] See Respondent’s Exhibit B.

[74]  March Report, p. 2.

[75]  March Report, p. 3.

[76]  March Report, p. 3.

[77]  March Report, p. 4.

[78]  August Report, p. 7.

[79] Dr. Childress’s testimony, p. 23, lines21-22.

[80]  Dr. Childress’s testimony, p. 170, line15.

[81]  Dr. Childress’s testimony, p. 169, line 24.

[82]  Dr. Childress’s testimony, p. 170, lines 7- 14.

[83]  Childress’s Report at p. 21.

[84]  Childress’s Report at p. 24.

[85]  S___’s testimony, p. 32, lines 15-17. S___ was asked, “Do you feel safe there?” She answered, “Yeah.” Id. at lines 18-19.

[86]  S___’s testimony, p. 5, lines 9-11 and p. 6, lines1-3.

[87]  R___’s testimony, p. 92, lines 12-19.

[88]  R___’s testimony at p. 95, lines 2-5.