Fathers make false allegations 16 times more frequently than mothers -in contested custody cases.


Received 2 July 2003; received in revised form 13 June 2004; accepted 20 June 2004 http://www.leadershipcouncil.org/docs/Trocme.pdf

Deliberate false reporting by fathers in contested custody cases is in fact much greater.  A study by Nicholas Bala (below) revised (above) and his colleagues found fathers make false allegations 16 times more frequently than mothers. 

These are mostly extreme abusers who do not believe his partner has a right to leave and are using the children to pressure her to return or punish her for leaving.  They have a tremendous sense of entitlement which they believe justifies any tactics including false reports.

Domestic Violence Abuse and Child Custody,  cited: S. J. Dallams & J.L. Silberg, "Myths that Place Children at Risk During Custody Litigation," 9(3) Sexual Assault Rep. 33 (Jan/Feb. 2006 and Jaffe, Crooks and Poisson "Common Misconceptions in Addressing Domestic Violence in Child Custody Disputes" 54 (4) J. & Fam. Ct. J. 57 (Fall, 2003)






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Fact Sheet #2: The myth of women’s false accusations of domestic violence and rape and misuse of protection orders

Fri, 28 May 2010 - 09:04 | Michael Flood

More articles about:



Women routinely make up allegations of domestic violence and rape, including to gain advantage in family law cases. And women use protection orders to remove men from their homes or deny contact with children.


  • The risk of domestic violence increases at the time of separation.
  • Most allegations of domestic violence in the context of family law proceedings are made in good faith and with support and evidence for their claims.
  • Rates of false accusations of rape are very low.
  • Women living with domestic violence often do not take out protection orders and do so only as a last resort.
  • Protection orders provide an effective means of reducing women’s vulnerability to violence.

Note that this fact sheet is also available in PDF. (See below.)

The myth

Fathers’ rights groups assert that women routinely fabricate allegations of domestic violence to gain advantage in family law cases and use protection orders to remove men from their homes or deny contact with children rather than out of any real experience or fear of violence. In its submission to a review of legislation regarding protection orders, the Lone Fathers’ Association (2004, pp. 11, 38) states that protection orders “are employed as a routine separation procedure” by women to force their husbands out of their homes, without any actual violence having occurred, “and/or as a vindictive retaliatory act”.

The facts

The risk of domestic violence increases at the time of separation.

There is no doubt that family court proceedings often are accompanied by allegations of domestic violence and the use of protection orders. However, this reflects the fact that domestic violence often escalates at the time of separation. Australian data from a national survey in 1996 show that women are as likely to experience violence by previous partners as by current partners and that it is the time around and after separation which is most dangerous for women (Australian Bureau of Statistics, 1996, p. 8).

Similarly, North American research documents that the risks of nonlethal and lethal violence are highest for women when they are leaving the male partners with whom they have been living in an intimate relationship (DeKeseredy et al., 2004, p. 677). Separated women are at elevated risk of violence by men, whether physical, sexual, or lethal, relative to women in intact unions (Brownridge, 2006), and women are at risk of increasingly severe violence when separating from violent partners (Riggs et al., 2000). The risk of post-separation violence decreases with the passage of time since separation, and is greatest in the first two or three months after the commencement of the separation, at least from homicide data.

Further situational variables influence post-separation violence. Leaving a marital or cohabiting relationship or trying to leave it increases women’s changes of being physically or sexually assaulted especially if they are connected to men with patriarchal and/or sexually proprietary attitudes (DeKeseredy et al., 2004). Women are at greater risk of post-separation violence if they are more ‘available’ for victimisation: if they live in the same city as their former partner, and at risker times such as court appearances and exchanges of or visits to children (Brownridge, 2006). The presence of a new partner can be either a risk or a protective factor, as can children. For example, joint custody may become an opportunity for conflict and violence, may increase opportunities for violence at visitation and the exchange of children, and children may be used as tools for violence by abusive men (Brownridge, 2006).

The relationship between pre- and post-separation violence is shaped by other variables such as the duration of the union and the severity and frequency of pre-separation violence. There is evidence that post-separation violence often is a continuation of violence that occurred during the relationship and that a substantial proportion of such violence is a new phenomenon (Brownridge, 2006).

Most allegations of domestic violence in the context of family law proceedings are made in good faith and with support and evidence for their claims.

Existing research finds that most allegations of domestic violence in the context of family law proceedings are made in good faith and with support and evidence for their claims. Two studies have examined rates of substantiated allegations of domestic violence in the context of family law proceedings, and they find that allegations are substantiated in 63 to 74 percent of cases (Shaffer and Bala, 2003; Johnston et al., 2005). The remainder are unsubstantiated – where either there is insufficient information to support substantiation or where there is a determination that the allegation is false.

A Canadian study of family law cases in which written decisions were produced over a three-year period identified 42 recorded cases of spousal abuse alleged against men. Seventy-four percent of these were substantiated. Only two cases of spousal abuse alleged against women were identified, one of which was substantiated (Shaffer and Bala, 2003). However, as the authors note, in the cases where the courts found the allegations to be exaggerated or unfounded, in some instances the courts gave no reasons for this conclusion, and in at least some cases, judges failed to recognise the existence or seriousness of actual abuse (Shaffer and Bala, 2003).

A US study drew on documentary records describing 120 divorced families referred for child custody evaluations and custody counselling, collected over 1989 to 2002 from family courts within San Francisco Bay Area counties. Multiple allegations of child abuse, neglect, and family violence were raised in the majority of cases. Allegations were assessed on the basis of detailed interviews with family members, information from professionals, and analysis of written documentation. This study found that 63 percent of allegations of abuse by one adult of another (including domestic violence and substance misuse) were substantiated (Johnston et al., 2005). Allegations were more likely to be substantiated against men than against women (67 versus 55 percent). In other words, counter to some popular perceptions, men rather than women were more likely to make allegations of domestic violence (and substance abuse) in family law proceedings which were not substantiated. However, this study cannot determine rates of false allegations, as it could not distinguish among ‘unsubstantiated’ allegations between those which were false and those which could not be determined due to lack of evidence (Johnston et al., 2005).

Rates of false accusations of rape are very low.

The evidence is that rates of intentionally false and/or malicious accusations of rape are very low. For example, the most recent British study determines that only three per cent of rapes reported to the police were either ‘possible’ or ‘probable’ false allegations (Kelly et al. 2005). Australian studies are similar. For example, in an analysis of 850 rapes reported to Victoria Police over three years, only 2.1 per cent of reports were identified by police as false (Statewide Steering Committee to Reduce Sexual Assault 2006: 5). Three earlier studies in Australia, based on police data from 1986 to 1990, find rates of false reports of sexual assault of 1.4 per cent, 4.8 per cent, and 7 per cent (VLRC 2004: 112).

Some other studies claim that rates of false allegations of sexual assault are much higher. However, as a recent review notes, there is considerable diversity in definitions of falsity, in how allegations are judged to be false, and in methods for collecting data regarding the extent of false allegations (Rumney 2006: 130-132). For example, some studies which find apparently high rates of false rape allegations take at face value the judgements made by police officers on the basis of stereotypical assumptions regarding rape victims and their responses to victimisation (ibid: 142).

There is no doubt that false allegations of rape and domestic violence sometimes are made. At the same time, there is nothing to suggest that these are common or that women make them more often than men (Davis, 2004). In addition, false allegations of violence and abuse are far less common than false denials of their perpetration (Jaffe et al., 2008).

Women living with domestic violence often do not take out protection orders and do so only as a last resort.

There is further evidence that most allegations of domestic violence express women’s genuine concerns for their and/or their children’s safety. Research in Australia finds that women going through family court proceedings and living with domestic violence do not routinely take out protection orders in response. In a study of 176 files in which children’s matters were contested, while 95 of the files (54 per cent) included evidence of domestic violence Apprehended Violence Orders had not been obtained in over a third of these (Melville & Hunter, 2001, pp. 127-128).

In addition, women often only take out protection orders against domestic violence as a last resort after being subjected to repeated and serious victimization (Melville & Hunter, 2001). Among young women aged 18 to 23, women are more likely to seek legal protection if they have experienced more severe levels of violence (e.g. including being beaten, choked or shot at), have been injured, and have children (Young et al., 2000, p. 3). Earlier research into the use of apprehended domestic violence orders found that the majority of complainants had experienced physical violence on more than one occasion (Trimboli & Bonney, 1997).

Legal authorities themselves reject the view that women routinely fabricate allegations of domestic violence. For example, bodies such as the Criminal Law Review Division of the NSW Attorney-General’s Department reject the view that women use protection orders in family law proceedings to gain a tactical advantage (Simpson, 2000, p. 18). In New Zealand, reviews by the Law Commission and the Ministry of Justice find no evidence to support the claim that women are making strategic use of protection orders, based for example on false allegations of domestic violence, to gain strategic advantage in family law cases (Davis, 2004).

In fact, Australian research finds that most women who have experienced violence in relationships still want their children to have some contact with the other parent, but what they seek (and often do not receive) is an arrangement which ensures safety for their children and themselves (Kaye et al., 2003).

Protection orders provide an effective means of reducing women’s vulnerability to violence.

The Australian evidence is that protection orders provide an effective means of reducing women’s vulnerability to violence. An early study in New South Wales found that the vast majority of complainants experienced a reduction in violence and abuse from the defendant in the six months after the order was served on the defendant, and over 90 per cent reported that the order had produced benefits such as reduced contact with the defendant and increased personal safety and comfort (Trimboli & Bonney, 1997). Finally, research among young women aged 18 to 23 and subjected to violence by intimate partners found that “preventive strategies for young women at the early stage of a relationship can eliminate, or at least reduce, physical violence by a partner” (Young et al., 2000, p. 5). The severity of violence was reduced after legal protection, but the benefit was not as marked unless women sought help from the courts as well as the police.

References cited

Australian Bureau of Statistics. (1996). Women’s Safety Australia (cat. no. 4128.0). Canberra: Australian Bureau of Statistics.
Brownridge, D. A. (2006). Violence against women post-separation. Aggression and Violent Behavior, 11(5): 514-530.
Davis, W. (2004) Gender Bias, Fathers’ Rights, Domestic Violence and the Family Court. Butterworths Family Law Journal, December: 299-312.
DeKeseredy, W. S., Rogness, M., & Schwartz, M. D. (2004). Separation/divorce sexual assault: The current state of social scientific knowledge. Aggression and Violent Behavior, 9, 675-691.
Jaffe, Peter G., Janet R. Johnston, Claire V. Crooks, and Nicholas Bala. (2008).  Custody disputes involving allegations of domestic violence: toward a differentiated approach to parenting plans. Family Court Review, 46(3): 500-522.
Johnston, J. R., S. Lee, N.W. Olesen, and M.G. Walters. (2005). Allegations and substantiations of abuse in custody-disputing families. Family Court Review, 43, 283–294.
Kelly L, Lovett, J & Regan, L 2005, A gap or a chasm? Attrition in reported rape cases, Child and Woman Abuse Studies Unit, London Metropolitan University, Home Office Research, Development and Statistics Directorate, London.
Lone Fathers Association Australia. (2004). Protection orders legislation review. (ACT). Discussion Paper: Comments by Lone Fathers Association. (Australia). Inc. Canberra.
Melville, A., & Hunter, R. (2001). ‘As everybody knows’: Countering myths of gender bias in family law. Griffith Law Review, 10(1), 124-138.
Riggs, D. S., M. B. Caulfield, & A.B. Street (2000). Risk for domestic violence: Factors associated with perpetration and victimization. Journal of Clinical Psychology 56(10): 1289-1316.
Rumney, N.S. (2006). False Allegations of Rape. Cambridge Law Journal, 65, March, pp.128-158.
Shaffer, M., and N. Bala. (2003). Wife abuse, child custody and access in Canada. In R. Geffner, R. S. Ingelman, & J. Zellner (Eds.), The effects of intimate partner violence on children  (pp. 253–276). New York: Haworth Maltreatment & Trauma Press.
Simpson, R. (2000). Incidence and regulation of domestic violence in New South Wales (Briefing Paper 4/2000). Sydney: NSW Parliamentary Library.
Statewide Steering Committee to Reduce Sexual Assault. (2006). Study of Reported Rapes in Victoria 2000-2003: Summary Research Report. Melbourne: Office of Women’s Policy.
Trimboli, L., & Bonney, R. (1997). An evaluation of the NSW apprehended violence order scheme. Sydney: NSW Bureau of Crime Statistics and Research.
VLRC 2004, Sexual offences: law and procedure: final report, Victorian Law Reform Commission, Melbourne.
Young, M., Byles, J., & Dobson, A. (2000). The effectiveness of legal protection in the prevention of domestic violence in the lives of young Australian women. Trends and Issues in Crime and Criminal Justice, 148, 1-6.


This Fact Sheet may be circulated. It may be reproduced with acknowledgement to Dr Michael Flood. Direct correspondence to mflood [at] uow.edu.au.


False Accusations DV Rape 2010.pdf
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The Evidentiary Admissibility of Parental Alienation by American Bar Association's Children's Legal Rights Journal

by Jennifer Hoult

Science, Law, and Policy, 26 American Bar Association, Child. Legal Rts J. 1 (Spring, 2006).


Since1985, in jurisdictions all over the United States, fathers have been awarded sole custody of their children based on claims that mothers alienated these children due to a pathological medical syndrome called Parental Alienation Syndrome ("PAS"). Given that some such cases have involved stark outcomes, including murder and suicide, PAS' admissibility in U.S. courts deserves scrutiny.

This article presents the first comprehensive analysis of the science, law, and policy issues involved in PAS' evidentiary admissibility. As a novel scientific theory, PAS' admissibility is governed by a variety of evidentiary gate keeping standards that seek to protect legal for a from the influence of pseudo-science. This article analyzes every precedent-bearing decision and law review article referencing PAS in the past twenty years, finding that precedent holds PAS inadmissible and the majority of legal scholarship views it negatively.

The article further analyzes PAS' admissibility under the standards defined in Fryev. United States, Daubert v. Merrell Dow Pharmaceuticals, Kumho TireCompany v. Carmichael, and Rules 702 and 704(b) of the Federal Rules of Evidence, including analysis of PAS' scientific validity and reliability; concluding that PAS remains an ipse dixit and inadmissible under these standards. The article also analyzes the writings of PAS' originator, child psychiatrist Richard Gardner - including twenty-three peer-reviewed articles and fifty legal decisions he cited in support of his claim that PAS is scientifically valid and legally admissible -finding that these materials support neither PAS' existence, nor its legal admissibility. Finally, the article examines the policy issues raised by PAS' admissibility through an analysis of PAS' roots in Gardner's theory of human sexuality, a theory that views adult-child sexual contact as benign and beneficial to the reproduction of the species.

The article concludes that science, law, and policy all support PAS' present and future inadmissibility.

To read full article click here (pdf)

© 2006 American Bar Association's Children's Legal Rights Journal


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Troubling Admission of Supervised Visitation Reports


Minnesota Center Against Violence and Abuse

by Nat Stern and Karen Oehme, J.d.

Supervised visitation programs provide services to courts in visitation and custody disputes in which a parent alleges physical or sexual abuse, domestic violence, or other harmful behaviors against a spouse or partner. Hailed as a welcome tool in the judicial management of high-conflict family court cases, these programs are garnering increased attention from legislatures, judges, and lawyers nationwide. The flurry of activity focused on funding and developing these programs,however, has obscured evidentiary questions arising from the visitation reports created at each visit. The widespread misuse of visitation reports, this article argues, threatens to compromise both the interests of abused children and the safety of domestic violence victims, whom supervised visitation was developed to protect.

Part I of this article explores the purposes of supervised visitation programs and the legal community's call for their development. Part II describes the efforts of legislatures and provider networks to develop standards and guidelines for the administration of supervised visitation services. Part III addresses issues surrounding the use and admissibility of observation reports and other reporting tools routinely kept by supervised visitation programs. Focusing on disputed custody cases with allegations of parental unfitness,3 this section examines the tendency of courts to call for program staff to make explicit evaluations based on visit interaction and the improper use of so-called "objective records." Finally, Part IV proposes a standard limiting the circumstances under which courts may admit program records into evidence in custody proceedings.

To read the complete article, click here

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National Council of Juvenile and Family Court Judges Rejects PAS


National Council of Juvenile and Family Court Judges. (2006). Navigating Custody & Visitation Evaluations in Cases with Domestic Violence: A Judge’s Guide (2nd edition). Reno, NV: NCJFCJ. (download PDF)

From page 24

Parental Alienation and the Daubert Standard: on Syndromes and Behaviors

In contested custody cases, children may indeed express fear of, be concerned about, have distaste for, or be angry at one of their parents. Unfortunately, an all too common practice in such cases is for evaluators to diagnose children who exhibit a very strong bond and alignment with one parent and, simultaneously, a strong rejection of the other parent, as suffering from "parental alienation syndrome" or "PAS".[52] Under relevant evidentiary standards, the court should not accept this testimony.

The theory positing the existence of "PAS" has been discredited by the scientific community.[53] In Kumho Tire v. Carmichael , 526 U.S. 137 (1999), the Supreme Court ruled that even expert testimony based in the "soft sciences" must meet the standard set in the Daubert [54] case. Daubert, in which the Court re-examined the standard it had earlier articulated in the Frye [55] case, requires application of a multi-factor test, including peer review, publication, testability, rate of error, and general acceptance. "Parental Alienation Syndrome" does not pass this test. Any testimony that a party to a custody case suffers from the syndrome or "parental alienation" should therefore be ruled inadmissible and/or stricken from the evaluation report under both the standard established inDaubert and the earlier Frye standard.[56]

The discredited "diagnosis" of "PAS" (or allegation of "parental alienation"), quite apart from its scientific invalidity, inappropriately asks the court to assume that the children's behaviors and attitudes toward the parent who claims to be "alienated" have no grounding in reality. It also diverts attention away from the behaviors of the abusive parent, who may have directly influenced the children's responses by acting in violent, disrespectful, intimidating, humiliating and/or discrediting ways toward the children themselves, or the children's other parent. The task for the court is to distinguish between situations in which children are critical of one parent because they have been inappropriately manipulated by the other (taking care not to rely solely on subtle indications), and situations in which children have their own legitimate grounds for criticism or fear of a parent, which will likely be the case when that parent has perpetrated domestic violence. Those grounds do not become less legitimate because the abused parent shares them, and seeks to advocate for the children by voicing their concerns.

52 "Parental alienation syndrome" was introduced by Richard Gardner and was primarily associated with child sexual abuse allegations in the context of contested child custody cases. For more information, see Bruch, supra note 28.

53 According to the American Psychological Association, "... there are no data to support the phenomenon called parental alienation syndrome ..." AM. PSYCHOL. ASS'N., supra note 2, at 40.

54 Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579 (1993).

55 Frye v. U.S., 293 F. 1013 (D.C. Cir. 1923).

56 These are federal standards, but many states adhere to them at least generally and should still exclude any proffered evidence of "PAS". http://www.stopfamilyviolence.org/pages/213

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Editors Intro To Custody and Abuse Issue of Violence Against Women

by Sage Publications, Violence Against Women

by Joan Zorza and Leora Rosen, Editors

This issue reports the results of four studies—all funded by the National Institute of Justice—that, for the first time, present systematically collected empirical evidence on the custody crisis facing battered women in America.

The question as to how many battered women lose custody of their children cannot be answered simply because the custody laws and practices governing normal custody arrangements vary from state to state, with the result that there are many different standards of comparison among the different jurisdictions. For example, in Florida, joint custody is the preferred arrangement, but parents may petition the court for sole custody in special circumstances. In addition, the data collected from courts typically involve contested custody cases, in which men who batter their intimate partners are likely to be over represented because they more often contest custody (American Psychological Association, 1996). There are also the issues of legal custody versus physical custody and restricted or structured visitation, or conditions placed on visitation. The studies in this issue deal with some of these multiple issues, with data collection having occurred in 9 of the 50 states.

This is by no means the last word, but hopefully it is the first.

To read complete introduction (pdf) click here

© 2005 Sage Publications, Violence Against Women

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Use of the MMPI-2 In Child Custody Evaluations Involving Battered Women: What Does Psychological Research Tell Us?.

Published by American Bar Assoc Family Law Quarterly

by Nancy S. Erickson

American Bar Association Family Law Quarterly Spring, 2005   39 Fam. L.Q. 87

Nancy S. Erickson J.D. Brooklyn Law School, LL.M. Yale Law School, M.A. in Forensic Psychology, John Jay College of Criminal Justice. The author was a professor of law in New York and Ohio and has written extensively on family law issues, es-pecially custody, domestic violence, and child support. She is currently a senior attorney at Legal Services for New York City, Brooklyn Branch. The views expressed in this article are solely the views of the author and do not necessarily reflect the positions or policies of Legal Services for New York City.

I. Introduction

The effects of domestic violence on survivors, who are primarily women, may be severe. Battered women's advocates often note that, in custody cases, the batterer often "looks better" to the court than the victim does because he is confident and calm, whereas she is still suffering the effects of his abuse and therefore may appear hysterical, weepy, angry, or otherwise not "together."

When a custody evaluation is conducted by a psychologist, the revised version of the Minnesota Multiphasic Per-sonality Inventory (MMPI-2) is often used as part of the evaluation process. The MMPI-2, like other traditional psychological tests, was not designed for use in custody evaluations and arguably should not be used for such purpose except "when specific problems or issues that these tests were designed to measure appear salient in the case."

However, if an evaluator chooses to use it, great care should be taken to make sure that it is not misinterpreted. A misinterpretation could result in placing custody of a child with a batterer, which could put the child at severe risk. Additionally, for many parents, especially those who have been primary caretakers, loss of custody of their children is the most frightening thing they can imagine, short of death. Loss of such an important liberty interest should not occur because of flawed information presented to the court by anyone, including one deemed to be an expert.

Abusers typically disavow any wrongdoing and claim the mother is "crazy" or unfit in some other way. The MMPI-2 cannot disprove a batterer's claim of innocence, because there is no known MMPI-2 abuser "profile."  In fact, many MMPI-2 profiles of batterers do not reveal any psychopathology.

Battered women, however, based on the results of the MMPI-2, may appear to be suffering from various psychopathologies, including but not limited to borderline personality disorder, paranoia, histrionic personality disorder, or even schizophrenia. The custody evaluator may conclude that the mother's apparent psychopathology is a personality disorder and therefore characterological (a "trait"). Personality disorders are viewed by many psychologists as highly treatment resistant and therefore curable, if at all, only with very long-term therapy and often psychotropic drugs. The custody evaluator might even conclude that the mother's apparent "psychopathology" caused the physical conflict between the parents.

Clinicians inadvertently maintaining such assumptions may examine a battered woman's profile and conclude, "Oh, no wonder she gets beat up. She's crazy, schizophrenic, borderline, and unstable," and the clinician may fail to investigate alternative conceptualizations for the woman's psychological presentation.

Failure to investigate other possible causes could even lead the custody evaluator to doubt whether the woman was abused at all - perhaps someone so unstable has made false allegations or perhaps she has attacked her partner and he has simply acted in self-defense.
An "alternative conceptualization" is that the woman's psychological presentation is a reaction to the abuse she has suffered (a reactive "state").

If battered women's MMPI elevations are reactive, one would expect that their MMPIs prior to being battered would be relatively "normal," that their MMPIs during the battering relationship would be elevated, and that their MMPI elevations would decrease after the abuse ended. Additionally, it might be expected that the severity of the abuse suffered by the woman or the length of time she was abused might correlate with the MMPI eleva-tions.

This article surveys the available research on battered women's MMPI/MMPI-2 profiles. That research tends to support the hypothesis that a battered woman's MMPI-2 profile often is a result of the abuse she has suffered (a reactive "state") and therefore should not be viewed by child custody evaluators as evidence that she has personality traits indi-cating that she would not be a fit parent.

To read the full article (pdf) click here

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Batterer Manipulation and Retaliation: Denial and Complicity In the Family Courts


by Joan Zorza, Esq.

Family Courts Excuse Male Misbehavior, But Blame Women

Most family and divorce (hereinafter, "family") court judges insist that people going through custody and divorce cases are good people, but that they often behave very badly because they are so stressed out by the pressures of the separation and court dispute. 1 The reality, as Massachusetts has found, is that nothing could be further from the truth for the men who abuse their female intimate partners and children (called either "abusers" or "batterers").

Massachusetts, which has since 1978 allowed its criminal court judges to issue restraining orders against abusers, and which now requires all judges--even the family ones, to consult offender probation records whenever a petition for protection in an abuse case is filed, keeps very careful records which it periodically analyses.  It has found that almost 80% of the male abusers have criminal records,2  46% for violent offenses, and 39% have prior restraining orders entered against them and 15% for violating of those orders within the first 6 months.  The men with prior orders are almost equally divided between those who have repeatedly abused one victim and those who have abusing multiple victims.3 Massachusetts also was the first state in the county to create a statewide registry for orders of protection, and it also enters orders of protection onto the defendants' probation records, so that judges automatically become aware of the defendants' prior record, even his juvenile one or cases which were later continued without any finding.  This is not to say that all abusive men have records or are abnormal,4  or that no female partners of abusers ever have records.  However, abusive men, although they tend to be considerably older, better educated and are more likely to be white than other criminals, and hence to have been given far more breaks in the criminal justice system, are simply not the stressed out good guys as the family courts assume.  Men who abuse do so as a matter of choice, as a way to assert power and control over their female partners, punish them, to be sexually aroused, or less often because they enjoy causing pain.5

    In contrast, although the family courts assign at least equal blame to the men's victims, the victims are generally no different than other women, except for having been abused and suffering the effects of that abuse. Prior to being abused, battered women are no different from other women.6 It is the effects of the abuse makes them frightened and show other effects, often making them appear less credible as witnesses.7 Courts, police and prosecutors often refuse to help battered women and discourage them from pursuing cases, but then blame them for dropping their cases.  In fact, battered women are no more likely to drop cases than are other victims of violent crimes who are being threatened by their abusers.  What is different is that most violent criminals never reassault or even contact their victims, but the average battered woman is beaten up three times by her batterer during the pendency of a criminal domestic violence case.8 All victims threatened with further assault want to drop their cases; battered women are actually more willing than other threatened victims to pursue their cases.9

Batterers are believed in blaming victims

Men who batter are not only adept at minimizing and denying their own abusive behaviors and their responsibility for it,  they are also adept at blaming circumstances or their victims, thereby shifting responsibility and projecting their own behavior onto their victims.10 Yet while alcohol,11 poverty, and other circumstances may aggravate a situation, they do not cause violence, as most people in such circumstances do not abuse.  Similarly, victims are not to blame for the violence. Unfortunately, abusive men have been very successful in convincing courts and juries that their own behavior is their female victims' fault, or that their partners provoked them, or wanted the abuse, or that bad circumstances caused the abuse.

Mental health experts lack expertise in family violence

Complicating the problem is that the courts often rely on mental health experts to evaluate the parties, yet overwhelmingly those experts have never received adequate training in domestic violence or child sexual abuse; indeed, their professional schools seldom teach the subjects and 40% of those working in mental health fields in the U.S. admit they have never received any training about intimate partner violence and even fewer received training about child sexual abuse.12 The content of what little training exists in schools in continuing education programs is often questionable or outright misleading, or so short (one hour is not that uncommon over the course of a career)13 that is clearly inadequate.  Guardians ad litem, who are supposed to represent the children's best interests to the court, generally lack training in any aspects of family violence or even child development.14  Only 10% of custody evaluators know enough about incest to not be dangerous in these cases.15 Without the training and sensitivity to abuse issues, few therapists and custody evaluators even screen for it or follow up when told about it. 16 When they do follow up, batterers are adept at manipulating mental health professionals, appearing very together and, if he admits the abuse, contrite and regretful, justifying his abuse or making it appear part of a substance abuse or depression problem or caused by his partner.17 All this convinces the professional that the abuse was an aberration that will be controlled in the future, although this is most unlikely.18 Mental health evaluators and guardians ad litem, having been trained in a system that blames mothers for most problems that people have,19 are particularly vulnerable to being persuaded by fathers who deny their abuse and blame their partners, with the result being that they discredit the mother's accusations and fears, and recommend that custody to go to fathers, even when the men are abusive.  The result is that domestic violence is seldom considered in the vast majority of  child custody determinations,20 particularly when there are allegations of physical or sexual abuse against a child.21 This is an amazing omission, given that at least 47 states and the District of Columbia require courts to consider domestic violence when making child custody determinations. (The three states which do not are Connecticut, Mississippi and Utah.)22

Judges, like mental health professionals, make the gender biased and inaccurate assumption that most domestic violence or child abuse accusations made in custody cases are falsely made for tactical gain, so take these cases far less seriously than they should.23 In fact, incest allegations are only made in 2-3% of custody cases, and mothers make few false accusations either of domestic violence24  or of child sexual abuse.25 Although no psychological test can definitively prove that someone has battered or sexually abused someone,26 many family courts require women to conclusively prove the abuse--a virtually impossible burden--or they refuse to believe that any abuse happened.

Furthermore, because most assessment tools used in custody evaluations were never developed to take into account the effects of domestic violence on victims, the tools distort the results to incorrectly show that most frightened victims are paranoid or have other psychiatric disorders, such as major depression, paranoid schizophrenia, dependent personality disorder, or borderline personality disorder,27diagnoses that will hurt her in any custody fight.28 Without experts able to refute the faulty diagnoses (and few battered women have the money to pay for such experts, even if any are available who are willing to criticize their colleagues), battered women and mothers of children who have been abused risk being assessed as incompetent mothers, and so lose custody.  Despite myths put out by fathers that mothers always win custody cases, fathers actually win custody in 70% of custody disputes,29 and this is true even though most men who abuse women and children are far more likely than other fathers to fight for custody and engage in prolonged litigation.30

Batterers Retaliate

Batterers do not only manipulate mental health professionals.  When batterers feel that their authority is being threatened, they escalate their violent and terroristic tactics, often threatening to kill or seriously injure their victims,31 their families, children or loved ones,32 and even themselves.33 After separation they often carry out these threats, hurting their partners 14 times as often after separation as when they were together.34 Most of these men also rape their female partners, and these rapes are more brutal than stranger rapes, and 10% of the rapes occur in from of the children.35 Batterers retaliate in many other ways as well, often being extremely imaginative and unpredictable.  They are notorious in fighting for custody,36 even though most of them never paid much attention to the children while then they were together with the children's mother.37 Most batterers seek the children knowing that depriving the mother of custody is the best way to punish and hurt her.38 Batterers, who are notoriously poor at paying child support,39 also know that winning custody not only absolves them from having to pay child support, it may obligate the mothers to pay them child support, which they see as another way to hurt the women.

Batterers also retaliate by threatening their former partners and her children during visitation, or by shifting their abuse onto the children. It is quite common for batterers to begin abusing the child physically or sexually after the separation, or for such abuse to escalate, just as their violence tends to escalate after separation against their former partners.40 Many threaten to and actually abduct the children,41 and these abductions are as harmful to the children as when strangers kidnap them.42

Even when batterers have custody, they often refuse to make let the mothers to see their children.  The same courts that are outraged when a mother fails to make the children available to the father seldom punish a father who denies visitation to the mother.

Some of these problems exist because of gender bias of individual judges, but other problems exist because the legislature has enacted laws that favor men.  While most states (Washington State is the exception) encourage courts to consider in granting custody which parent will encourage a better relationship and frequent contact between the children and the other parent, courts consider only behaviors that mothers are more likely to do under this criteria, leaving out behaviors that men primarily do.  Thus failing to pay spousal or child support, or failing when one could do so to legitimate the other parent's immigration status are not seen as hurtful.  Yet what could be more harmful to a relationship with the children than depriving the other parent of adequate support or even the right to remain in the U.S.  Indeed, changing custody because a parent has not paid child support is illegal in most states, yet custody is changed all the time when mothers do not give father access to their children.

Another way that some men retaliate is by having their parents join in the fight for custody or visitation (of course, some grandparents, often the ones from whom their son learned to be abusive in the first place, do this spontaneously).  Fortunately, this was made much harder by Troxel v. Granville43,  the recent U.S. Supreme Court decision which struck down Washington State's grandparent visitation statute that permitted visitation against the wishes of the parents.  Both batterers and paternal grandparents and batterers also often file false or trumped up charges against their daughters-in-law or sons' girlfriends to get them in trouble and discredit them, most often with child protection agencies, but also alleging welfare or immigration fraud or criminal activity, but also in court.44

Another reason that courts have not been quicker to catch on about men's projecting their own behaviors onto their victims45 and vindictiveness against their former female partners is that while they speak very negatively about their former partners, they generally speak very positively about their current ones.46 This is typical of men, but few courts or mental health practitioners are aware of it, and are fooled into thinking the men must be  objective, and thus what they say about their former partners must be accurate.  Yet once the men break up with their current partners they will start publicly devaluing.

Some courts are wising up to men's retaliatory tactics, because many involve abusing the courts. Many abusers learn that cross or counterclaims often cancel out their victims; prior claims, and that filing contempts shifts the focus to their victims.47 Most batterers know they can bring criminal and contempt charges at no expense to the abusers, but they take an enormous financial and emotional cost on their victims.  The result is that many abusive men drag on the litigation and file spurious claims openly acknowledging they are trying to drive their victims onto welfare or into homelessness; half of all homeless women and children in the U.S. are homeless because of domestic violence.48 Occasionally it is only when the abuser accuses the judge or other court players of impropriety or attacks them or those helping their partners, such as shelter workers,49 that the court catches on to their tactics. Unfortunately, some judges (and other court players, including mental health experts) become too frightened50 or vicariously traumatized51 to act sufficiently to believe or act to protect battered women. However, most abusers are far too savvy to make such accusations, attacking only their former partners.

When courts blame victims and fail to hold abusers accountable, they reinforce abuser behavior, subvert justice, disempower the victims, teach children that abusive behavior is permissible and may even be rewarded, and reinforce the cycle of violence.


  1.    ABA Center on Children and the Law & State Justice Institute, A Judge's Guide: Making Child-Centered Decisions in Custody Cases, 4 (Chicago, IL: ABA,  2001).

2.    James Ptacek, Battered Women in the Courtroom: The Power of Judicial Responses, 89 (Boston, MA: Northeastern University Press, 1999).

3.    Donald Cochran, Sandra Adams & Patrice O'Brien, From Chaps to Clarity in Understanding Domestic Violence, 3 Domestic Violence Report 65, 77-78 (1998). ).

4.    American Psychological Association , Violence and the Family: Report of the American Psychological Association Presidential Task Force on Violence and the Family, 37 (Washington, DC: Author, 1996). [Hereinafter, APA.] ).

5.    Evan Stark & Anne H. Flitcraft, Spouse Abuse. In Violence in America: A Public Health Approach, 123, 132-33 (Mark L. Rosenberg & Mary Ann Fenley, eds., New York: Oxford Press, 1991); Ola W.  Barnett & Alyce D. LaViolette, It Could Happen to Anyone, 63 (Thousand Oaks, CA: Sage, 1993). ).

6.   Stark & Flitcraft, supra note 6, at 140-44. ).

7.    Id., at 134. ).

8.    Joan Zorza, Battered Women Behave Like Other Threatened Victims, 1(6) Domestic Violence Report 5 (August/September 1996). ).

9.    APA, supra note 4, at 37. ).

10.   Id., at 81-82. ).

11.   Barnett & LaViolette, supra note 5, at 77. ).

12.   Felicia Cohn, Marla E. Salmon, & John D. Stobo, Confronting Chronic Neglect: The Education and Training of Health Professionals on Family Violence, 3-5 to 3-8 and 4-5 (Washington, DC: National Academy Press, 2001). ).

13.   Id., entire book; APA, supra note 3, at 13. ).

14.   APA, supra note 4, at 102. ).

15 .  John E.B. Myers, A Mother's Nightmare  Incest: A Practical Guide for Parents and Professional, 104 (Thousand Oaks, CA: Sage, 1997). ).

16.   Edward W. Gondolf & Ellen W. Fisher, Battered Women as Survivors, 133-34 (New York: MacMillan, 1998). ).

17.   Id, at 132. ).

18.   Id., at 81. ).

19.   Barnett & LaViolette, supra note 5, at 9-10. ).

20   Joan Zorza, Domestic Violence Seldom Considered in Psychologists' Custody Recommendations, 2 Domestic Violence Report, 65 and 68 (1997).

21.   Myers, supra note 15.  Mothers of abused children are themselves blamed for the abuse and traumatized by it and other's reactions. See, e.g., Betty Joyce Carter, Who's to Blame? Child Sexual Abuse and Non-Offending Mothers, 188 (Toronto, Ontario: University of Toronto Press, 1999). ).

22.   Linda D. Elrod & Robert G. Spector, A Review of the Year in Family Law: Redefining Families, Reforming Custody Jurisdiction, and Refining Support Issues, 34 Family Law Quarterly 607, 652 Chart 2 (2001).).

23.   A Typical Week of Restraining Orders in Massachusetts,1(4) Domestic Violence Report 3, 4 (April/May 1996). ).

24.  APA, supra note 4, at 12. ).

25.  Id.

26.   Myers, supra note 15, at 46-48.

27.   Edward W. Gondolf, Addressing Woman Battering in Mental Health Services, 81 (Thousand Oaks, CA: Sage, 1989). ).

28.   Barnett & LaViolette, supra note 5, at 74; Gondolf, supra, note 16, at 81. ).

29.   Ruth I. Abrams & John M. Greaney, Report of the Gender Bias Study of the Supreme Judicial Court [of Massachusetts],  62-63 (1989), also citing similar findings from California and the entire nation. ).

30.   APA, supra note 4, at 40. ).

31.   David Adams, Identifying, Assaultive Husbands in Court: You Be the Judge, 33 Boston Bar Jounal, 23-24 (July/August, 1989). ).

32.   Id.; Barnett & LaViolette, supra note 5, at 50.

33.  Donald Dutton & Susan K. Golant, The Batterers: A Psychological Profile, 49 (New York: BasicBooks, 1995). ).

34.   Caroline Wolf Harlow, Female Victims of Violent Crime, 5, Dept. of Justice, Bureau of Statistics, NCJ-126826 (January 1991). ).

35.   Ptacek, supra note 2, at 74; Lenore E. Walker, The Battered Woman Syndrome, 48 (New York: Springer Publishing Co., 1984); Jacquelyn Campbell, Community Nursing Department, Wayne State University College of Nursing, Nursing Assessment for Risk of Homicide with Battered Women (1986). ).

36.   Barnett & LaViolette, supra, note 5, at 50; APA, supra note 4, at 100; Marsha .B. Liss & Geraldine Butts Stahly, Domestic Violence and Child Custody, in Battering and Family Therapy: A Feminist Perspective, 175, 179 & 181 (Marsali Hansen & Michèle Harway, eds., Thousand Oaks, CA: Sage, 1993) ).

37.   Catherine Kirkwood, Leaving Abusive Partners, 54-55 (1993); Einat Peled & Duane Davis, Groupwork with Children of Battered Women: A Practitioners' Manual, 8 (Thousand Oaks, CA: Sage, 1995). ).

38.   Liss & Stahly, supra note 36, at 179. ).

39.   Id., at 181; Mildred Daley Pagelow, Family Violence, 311 (1984). ).

40.   Harlow, supra note 35. ).

41.   Geoffrey L. Grief & Rebecca L. Hager, When Parents Kidnap 4 (1992). ).

42.   Id., at 205-206. ).

43.   530 U.S. 57 (2000). ).

44.   Zorza, supra note 21, at 68 & 75. ).

45.   Dutton & Golant, supra note 34, at 105. ).

46.   David Schuldenberg & Shan Guisinger, Divorced Fathers Describe Their Former Wives: Devaluation and Contrast, Women and Divorce/Men in Divorce: Gender Differences. In Separation, Divorce and Remarriage, 61-87 (Haworth Press, 1991). ).

47.   Jeffrey L. Edleson & Richard M. Tolman, Intervention for Men Who Batter: An Ecological Approach, 31 & 34 (Thousand Oaks, CA: Sage, 1992). ).

48.   Joan Zorza, Woman Battering: A Major Source of Homelessness, 25 Clearinghouse Review, 421 (!991). ).

49.   Ptacek, supra note 2, at 63. ).

50.   Id. ).

51.   Joan Zorza, Why Courts Are Reluctant to Believe and Respond to Allegations of Incest. In The Sex Offender: Theoretical Advances, Treating Special Populations and Legal Developments, Vol. III, 33-8 (Barbara K. Schwartz, Ed., Kingston, NJ: Civic Research Institute, 1999).

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