Running head: OUR CORRUPT COURTS 1

Our Corrupt Courts: How Family Courts Endanger Children Nationwide

Liam C. Conant

First Colonial High School

OUR CORRUPT COURTS 2

Abstract

In this paper, the author will describe the corruption that exists in the United States family court

system. This corruption leads to thousands of children being placed in the hands of abusive

parents. The author describes many of the facets in which corruption manifests itself in the

family court system, including Parental Alienation Syndrome, and Guardians Ad Litem. The

author includes both anecdotal and statistical information that will provide a clear picture of the

corruption that exists in the United States family court system.

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Corruption

40-50% of married couples divorce ("Marriage and Divorce," n.d.). Most of the time,

following a divorce, the separated couple will enter into divorce court, in order to determine

division of assets, division of property, division of debt, and most importantly, who gains

custody of the child. The family court systems are supposed to protect and act in the best

interests of the child, however that is not always the case. More than 58,000 children are placed

in unsupervised contact with a physically or sexually abusive parent per year ("How Many

Children Are Court -Ordered Into Unsupervised Contact With an Abusive Parent After

Divorce?," 2008). Since 2008, at least 618 children have been murdered “by a parent involved in

a divorce, separation, custody, visitation, or child support situation” ("U.S. Divorce Child

Murder Data," 2017). These children are being placed in the care of abusive parents because of

the corruption that exists in the United States’ family court systems. Merriam-Webster defines

corruption as “dishonest or illegal behavior especially by powerful people”. The Family Court

system in the United States is corrupt, and through pseudosciences, lack of uniformity between

states, and lack of disciplinary policies for family court officials, allows children to be placed in

the hands of abusive parents.

Anecdotal Evidence

These following stories serve as a proof for the widespread corruption in the family

courts. These stories embody many of the issues discussed in this paper, and present them in the

form of people’s real-life experiences.

Laura Jeu

Laura Jeu knew something was wrong when her mother, Sharon, returned from a custody

hearing, telling her and her three siblings to get ready to see their father, Raphael. Laura knew
OUR CORRUPT COURTS 4

this would not be a normal visitation in her parent’s six-year long battle for custody. The

children were ordered to go with their father to a four-day workshop in California to bond and

work out their relationship. In order to do this, the judge presiding over their case had to perform

two controversial legal decisions. First, the judge had to give Raphael full custody of the

children, and second, the judge had to order that the children have no contact with their mother

for 90 days. The judge warned Sharon that if she did not convince her children to go, then there

would be a warrant issued for her arrest. Laura and her siblings refused to go, causing Sharon to

call an emergency psychiatric unit, which failed to convince the children to enter the car to visit

their father. Desperate, Laura called Sharon’s attorney, saying that she, along with her siblings,

were suicidal. The children were then taken to the emergency room, and soon after, Raphael

arrived, to take the children with him. The children remained with Raphael in his home for two

weeks, until one night. The children were awoken by several adults, and Raphael. The adults,

from a youth transport service, separated the children into cars and were sent off in different

directions. Laura was taken to Dulles International Airport, while her three brothers were sent to

Baltimore-Washington International Marshall Airport. Terrified and alone, they all boarded

flights to California. It would be a year before the children saw their mother again. Laura and her

siblings are part of a growing number of children being sent to “reunification” programs, in order

to treat Parental Alienation Syndrome (PAS), a term coined by psychologist Richard Gardner in

1985. Sharon and her children alleged that Raphael would be physically abusive toward them,

which Raphael vehemently denied. In 2004, Sharon took the children and left, and in 2005,

Raphael sued for custody of the children. The judge decided to grant joint custody to Sharon and

Raphael, with the children going to Raphael’s house every other weekend. The children refused

to go. They reported abusive incidents to the court, and to their therapists; however, the judge
OUR CORRUPT COURTS 5

allowed the visits to continue (Tabachnick, 2017). A 2011 study for the National Institute of

Justice, conducted by Daniel Saunders, found that 47% of evaluators recommend unsupervised

visits, even with reports of violence in the family (Saunders, Faller, & Tolman, n.d.).

Annalise Rice

Annalise Rice, 19 years old, filed a lawsuit against her father, Brent Rice, Hennepin and

Carver counties, and a number of others involved in her family court case, that she says, violated

her civil rights. Her lawsuit seeks $240 million total, and $15 million from Brent. She alleged

she was forcefully taken from her mother, and forced to live with an abusive father. She argued

in her lawsuit that the family court used pseudoscience and false testimony to support the

decision for her to live with her father. Her lawsuit states, in part:

By coercing and financially harassing Plaintiffs mother into abandoning her legal

efforts to protect Annelise through the courts, by knowingly allowing the

introduction of false testimony, by allowing into evidence and/or the court’s

consideration the bogus, disreputable, and pro child-abuser ‘Parental Alienation

Syndrome’ theory concocted by the discredited misogynist Richard Gardner, by

failing to disclose to the court the unethical and prejudicial relationship between

Defendant Brent Rice and Defendants, by prohibiting Annelise Rice (or any older

siblings) from testifying on her own behalf in order to obtain protection from the

abuse, by falsifying child protective services reports on Plaintiffs abuse, and other

acts. (Rice v. Rice, 2017)

Annalise said Brent beat her and her mother “Since I could remember.” Her mother filed

a restraining order against Brent when Annalise was in third grade. About a year later, the

guardian ad litem for the case, Susan Olson, took Annalise to Brent’s house. She told Annalise
OUR CORRUPT COURTS 6

she would no longer be living with her mother, and would be living with Brent from now on, and

offered no explanation to Annalise as to why. The court, and Olson accused Annalise’s mother

of inducing Parental Alienation Syndrome on Annalise. This accusation led to the court granting

Brent sole custody of Annalise. Brent was mostly absent in Annalise’s life; however, she says,

when he was around, he was abusive. After one incident of abuse, Annalise fled Brent’s home,

and walked to her grandparents house, alone. Her grandparents filed a restraining order against

Brent, which resulted in Annalise being ordered to live with her grandparents. Eventually,

Annalise was ordered to live with Brent again, and she was told, if she ran away again, she

would be sent to juvenile hall. During this period of living with her father, Annalise became

suicidal. She soon made contact with a close family friend, who put her into contact with her

mother. The two escaped to Canada; however, they crossed into Michigan, and were promptly

detained. Annalise’s mother was charged with parental deprivation and given a two month

sentence in prison, but her conviction was soon overturned. Annalise was taken back to Brent’s

house, where she spent most of her time with friends, and tried to avoid her father as much as

possible. When she turned eighteen, Annalise left her father’s house, cutting off all contact with

him (Volpe, 2017).

San Diego Lawsuit

A federal class action lawsuit was filed in 2013, naming numerous judges, lawyers, and

other San Diego divorce court professionals as defendants. The suit accuses the defendants of

participating in a racketeering scheme of attempting to drive up court costs via orders, and

delaying cases. The suit was filed by California Coalition for Families and Children, a group that

is “devoted to protecting parents’ and children’s interests in divorce, custody, and parentage

matters” (CALIFORNIA COALITION FOR FAMILIES AND CHILDREN, 2013). The US

OUR CORRUPT COURTS 7

district court initially rejected the suit, with Judge Cathy Ann Bencivengo criticizing the

plaintiffs for submitting a complaint of 175 pages, and 1100 pages of exhibits. The judge said

that the claim was “unmanageable, argumentative, confusing, and frequently incomprehensible.”

The plaintiffs rebutted that, although their brief was long and complex, the law is as well. The

Coalition was successfully able to repeal their case. They asked the appeals court to limit the

judicial immunity granted to judges and “custody evaluators” in family court cases. Attorney

Matt Green said that the suit “fails to allege facts with sufficient particularity showing a

conspiracy involving any judicial defendant”. Eileen Theofanous Lasher replied to this comment,

stating that she had seen many cases in which judges and divorce attorneys colluded in order to

extend a divorce case (McDonald, 2016).

Gag Orders

The Cornell Law Dictionary defines a gag order as “A judge's order prohibiting the

attorneys and parties in a pending lawsuit or criminal prosecution from talking about the case to

the media or the public.” The family court systems often use gag orders as tools to prevent

parents from speaking out about their case. When courts issue gag orders in criminal or civil

cases, they are most of the time issued in order to ensure the defendant receives a fair trial

("Sheppard v. Maxwell, 384 U.S. 333 (1966)"). However, in the family court system, gag orders

serve another purpose entirely, oftentimes restricting parents enmeshed in family court affairs

from speaking out about their case.

In the case of Nichols v Sivilli, Sivilli is a judge that presided over the case of Myronova

v. Malhan. Nichols is a reporter that wished to interview one of the litigants in the case of

Myrnova v. Malhan. In Myrnova v. Malhan, Myrnova was granted full custody of the children

after she alleged that Malhan was an unfit parent. Sivilli issued a gag order on the case,
OUR CORRUPT COURTS 8

preventing both litigants from speaking about the case to any form of media outlet, including

preventing them from speaking about the divorce online. Nichols alleged that the court stripped

Malhan of his due process, not allowing him to present evidence or question Myrnova, in order

to prove his parental fitness. Malhan attempted to enjoin the gag order, but he was denied this.

Another judge, Judge Wolfson, said that gag order “raises serious constitutional concerns” and

“failed to meaningfully weigh Plaintiff's First Amendment rights" (United States District Court,

D. New Jersey., "NICHOLS v. SIVILLI | Civ. No. 2:14-3821 (WJM). | 20141219c31"). Nichols

filed suit against Sivilli and the Essex County Superior Court, challenging the constitutionality of

the gag order placed on Malhan. He said the order prevented him from interviewing Malhan

about the case, something that he said “are a matter of public interest.” He further contended that

Sivilli did not hold plenary hearings, and did not weigh the First Amendment implications

brought about by this gag order, and instead based the gag order off of “a generalized finding

that publicity in family court is not in the best interests of children" (United States District Court,

D. New Jersey., 2014).

Parental Alienation Syndrome

Parental Alienation Syndrome (PAS) is a term created by Richard Gardner in 1985 in

Recent Trends in Divorce and Custody Litigation. PAS is a syndrome in which a parent (the

alienating parent) will ‘brainwash’ a child into hatred of the other parent (the alienated parent),

via denigration of said parent and false claims of abuse in order gain sole custody of the child for

themselves, or reduce the custody rights of the other parent (Bruch, 2002). Oftentimes the

alienating parent will convince the children into believing false claims of abuse, and children

will often create their own fabricated stories of abuse (Gardner, 1985). Gardner recommends that

children spend long periods of time with the alienated parent, in order to rehabilitate the
OUR CORRUPT COURTS 9

relationship between alienated parent and the child (Smith, n.d.). This situation occurred in the

case of Laura Jeu, her mother was falsely accused of PAS by her abusive father, Raphael. The

accusation led to the judge presiding over her case giving Raphael full custody of Laura and her

siblings.

Gardner also states that PAS is present in 90% of children involved in custody cases,

with no research to back up this statistic (Bruch, 2002). There are many holes and many flaws in

Gardner’s theoretical syndrome. Although it seems like PAS would be an effective tool for

determination of which parent is being abusive, most of the time this is not the case. Many

times, an abusive parent will use an accusation of PAS, in order to cover up allegations of abuse

from the other parent, or the child. The abusive parent will do this in order to gain custody of the

children from the non-abusive parent.

There are many negative implications regarding PAS. In A Judicial Guide to Child Safety

in Custody Cases, by the National Council of Juvenile and Family Court Judges, stated that

“Under relevant evidentiary standards, the court should not accept testimony regarding parental

alienation syndrome” (Bowles, Christian, Drew, & Yetter, 2008). They stated that testimony

regarding PAS should not be accepted because it does not meet the standard set in the Daubert

case. Under Daubert, it “requires application of a multi-factor test, including peer review,

publication, testability, rate of error, and general acceptance” (Bowles, Christian, Drew, &

Yetter, 2008). PAS does not meet this standard. The American Psychological Association did not

find sufficient data supporting the theory of PAS, which raised concerns of the theory’s use

(American Psychological Association, n.d.). Many of Gardner's findings in his studies are based

on his own clinical studies, with no peer-reviewed studies to back up his findings (Meier, 2009).

Guardian Ad Litem
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A Guardian Ad Litem (GAL) is a person appointed by the court, and in the family courts,

are chosen to represent “the best interests of the child” during court proceedings (Forman, n.d.).

GAL’s are often attorneys, however, in some states such as Florida, GAL’s can be non-attorneys.

These non-attorney GAL’s are known as “lay guardians”. These GAL’s work as investigators for

the courts. They investigate all aspects of the case, speak to all parties involved, view documents

and other information that may be beneficial to their investigation, then write a report based on

their findings. This report entails what the GAL found in their investigation, and makes

suggestions on what they think would be in the best interests of the child ("What Does a

Guardian Ad Litem Do in a Family Court Case?," n.d.). This is the core duty of a GAL, however

GAL’s often do not completely perform these tasks, or utterly fail to perform them. Rules for

GAL behaviour and guides for what a GAL should do during an investigation are established by

each state’s Supreme Court (C. I. Eveleigh, Personal communication, November 29, 2017). In

some states, such as Virginia, these rules and guidelines are merely suggestions, making it easy

for a GAL to perform these duties negligently, or to not perform these duties at all. In these states

where GAL’s operate under suggested rules and guidelines, it is very difficult to discipline a

GAL for negligence, or malpractice (C. I. Eveleigh, Personal communication, November 29,

2017). If a GAL fails to perform these duties, they may make incorrect statements in their GAL

report, which can result in a judge issuing a custody decision that would not be in the best

interests of the child. GAL’s are often granted immunity from lawsuits related to their

investigations, in order to prevent them from being sued by parents who simply did not like the

outcome of their case. This immunity allows for GAL’s to make decisions impartially, and in the

best interest of the child, without fearing litigation from the parties involved (Laurent, 2004). In

the case of Logan Marr, she was placed under the care of GAL Lawrence Irwin. Logan was then
OUR CORRUPT COURTS 11

placed into state custody, and placed in a foster home. Shortly after being placed in this foster

home, Logan had to be removed due to abuse. Logan was moved to another foster home, where

she again experienced physical abuse and neglect. The abuse continued until Logan died due to

suffocation from being wrapped in duct tape. Logan’s mother, Christy Marr, was outraged, and

filed a lawsuit against Lawrence Irwin, the State of Maine, and the Department of Human

Services. Christy Marr alleged that Irwin failed in his duties as a GAL. These failures include:

failure to investigate the foster homes Logan was placed in, failure to meet with Logan before

her court hearings, failure to know that one of the foster parents Logan was placed with was not

a registered foster parent at the time. Christy Mar further alleged that Irwin, who had served as a

GAL in the past, was “aware of the risk of harm attendant to the failure to monitor and control a

child’s progress while in state care” and that he “failed to take easily available measures to

address that risk.” The suit claimed malpractice, negligence, and wrongful death. Irwin filed to

dismiss in trial court, and this motion was granted, based on Irwins argument that he, as a GAL,

was protected by quasi-judicial immunity (Laurent, 2004). Are GAL’s always entitled to

immunity from suit when they don't perform their basic duties? GAL’s are advocates of the best

interests of a child. GAL’s do not represent the wishes of the child (IN RE MARRIAGE OF

WIEDERHOLT v. FISCHER). GAL’s are only entitled to quasi-judicial immunity under certain

circumstances. When a GAL is appointed to a case, they are supposed to act as an arm of the

court. However if a GAL does not act in this way, if a GAL acts as an advocate of the child's

wishes, insead of the best interests of the child, then a GAL should not be granted quasi-judicial

immunity from suits related to the case they are assigned. These GAL’s would be held liable for

any malpractice or negligence during their time on the case (Collins v. Tabet).

H. CON. RES. 150

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H. CON. RES. 150 is a concurrent resolution introduced in the United States

House of Representatives by Republican representative Ted Poe, on September 9, 2016. The

resolution describes child abuse as a “major public health issue in the United States.” Financial

costs of confirmed child maltreatment cases (including physical abuse, sexual abuse,

psychological abuse, and neglect) in one year are estimated to amount to $124 billion. H. CON.

RES. 150 recognized that allegations of abuse are often neglected in child custody litigation,

resulting in children being placed with abusive parents. The resolution also found that family

courts often use “scientifically unsound theories” such as parental alienation, in order to dismiss

allegations of abuse. It makes suggestions for improvements in the state courts. These

suggestions would greatly improve the state of the family courts, and help to prevent further

corruption of the family court system:

(1) child safety is the first priority of custody and visitation adjudications, and courts

should resolve safety risks and claims of family violence first, as a fundamental

consideration, before assessing other best interest factors; (2) quasi-scientific evidence

should be admitted by courts only when it meets admissibility standards for scientific

evidence; (3) evidence from court-affiliated or appointed fee-paid professionals regarding

adult or child abuse allegations in custody cases should be considered only when the

professional possesses documented expertise and experience in the relevant types of abuse,

trauma, and the behaviors of victims and perpetrators; (4) States should define required

standards of expertise and experience for appointed fee-paid professionals who provide

evidence to the court on abuse, trauma and behaviors of victims and perpetrators, should

specify requirements for the contents of such professional reports, and should require courts

to find that any appointed professionals meet those standards; (5) States should consider
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models under which court-appointed professionals are paid directly by the courts, with

potential reimbursement by the parties after due consideration of the parties’ financial

circumstances; and (6) Congress should schedule hearings on family courts’ practices with

regard to the objective, fair, and adjudication of children’s safety and civil rights.

With the passing of this resolution, judges and lawyers would no longer be able to use

accusations of PAS as justification for placing children with abusive parents.

AMENDMENT: 4/13/18:

Following the conclusion of writing this paper, it had come to my attention the existence

of H.Con.Res.72, a concurrent resolution introduced in the United States House of

Representatives on July 24, 2017. This resolution contains nearly the same text as

H.Con.Res.150, save for the following portion. In the text of H.Con.Res.150, it records a number

of 175 children that had been “ killed in a 2-year period by parents involved in divorce,

separation, custody, visitation, or child support proceedings”(H.R. H.Con.Res.150, 2016).

Comparatively, in the text of H.Con.Res.72, it records a number of 568 children who were killed

“10-year period by a parent involved in a divorce, separation, custody, visitation, or child support

proceeding” (H.R. H.Con.Res.72, 2017). Aside from the differences in the length of time these

deaths had been recorded, the text of these resolutions remain relatively the same, outside of any

minor grammatical changes.

Conclusion
OUR CORRUPT COURTS 14

The Family Court system in the United States is corrupt, and through false usage of

Parental Alienation Syndrome, and absolute immunity for Guardians Ad Litem and family court

judges, allows children to be placed in the hands of abusive parents. Through the heartbreaking

stories of Annalise Rice and Laura Jeu, the corruption of the United States family courts come to

life. Parental Alienation Syndrome, a powerful tool that can be used by abusers, in order for

them to gain custody of their child. Gag orders, that prevent parents enmeshed in this dangerous

system from speaking out about the atrocities that take place inside the courtrooms. Guardians

Ad Litem, who are supposed to represent the best interests of the child, are free to act negligently

and maliciously, without fear of legal repercussions. A Congressional resolution, that could

potentially fix these problems that exist within the United States family court system, and allow

all who have struggled in their battle for justice to breathe a collective sigh of relief.
OUR CORRUPT COURTS 15

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