April 24, 2026 – Parental Alienation

“There has been much research over the past decades in relation to the concept of alienation and other parent-child contact problems. In Ontario, Dr. Barbara Jo Fidler, Pr. Nicholas Bala, Pr. Rachel Birnbaum, Pr. M.G. Saini and Dr. Shelley Polak, among others, have been prolific researchers and writers on this very challenging topic. In a recent article penned by Dr. Fidler and Pr. Bala, they explain that there are many possible intersecting predisposing, precipitating and perpetuating factors that can contribute to the development of different types and cases of parent-child contact problems. Widely recognized factors include:

          1. child factors (age, cognitive capacity, temperament, vulnerability, special needs and resilience);
          2. parent conflict before and after the separation;
          3. sibling relationships;
          4. favoured parent factors (parenting style and capacity, negative beliefs and behaviours, mental health, and personality, including responsiveness and willingness to change);
          5. rejected parent factors (parenting style and capacity, negative reactions, beliefs and behaviours, mental health, and personality, including willingness to change);
          6. the adversarial process/litigation;
          7. third parties such as aligned professionals and extended family; and
          8. lack of functional coparenting, and poor or conflictual parental communication.

According to these authors, there is a growing consensus among those who use the concept of alienation about typical behaviours and perceptions exhibited by an alienated child, favoured parent, and rejected parent which lead to a conclusion that a parent is engaging in alienating behaviours. After reviewing 58 studies of parent-child contact problem cases in 2016, researchers found that “there is remarkable agreement on the behavioural strategies parents can use to potentially manipulate their children’s feelings, attitudes, and beliefs in ways that may interfere with their relationship with the other parent. The cluster of symptoms or behaviour indicating the presence of alienation in the child can also be reliably identified.” See M.A. Saini, J. Johnston, B.J. Fidler, & N. Bala, “Empirical studies of alienation”, in Leslie Drozd, M.G. Saini, and Nancy Olesen, Parenting Plan Evaluations: Applied Research for the Family Court, 2 ed (New York: Oxford Academic, 2016); Fidler & Bala, 2020. Typical behaviours in those cases include:

          1. portraying the other parent as dangerous;
          2. exaggerating and exploiting the other parent’s behaviour, negative attributes and challenges;
          3. undermining;
          4. parentifying the child;
          5. oversharing legal and other inappropriate information with children;
          6. co-opting children as messengers, spies and confidants;
          7. conspiring with children to withhold information, keep secrets and mislead the other parent;
          8. surreptitiously contacting the children when they are with the other parent;
          9. withholding parenting time and being inflexible around scheduling;
          10. withholding love and affection from the child if they do not share and act on the parent’s views;
          11. disparaging the other parent’s family members;
          12. co-opting neighbours, therapists, school personnel and others in an effort to garner support and turn them against the other parent; and
          13. believing it is their right, supporting or permitting a child or adolescent to make a life altering decision to never see a parent again.

Alienating behaviours also include what the parent does not do, such as actively supporting the child’s relationship with the other parent, failing to correct the child’s defiant, aggressive, destructive, and omnipotent behaviour, or without admonishment permits the child to change the established practice and refer to and call the other parent by their first name: Same as above. See also Fielding v. Fielding, 2013 ONSC 5102, 39 R.F.L. (7th) 59, at paras. 136-143.

It is also widely accepted that there is a wide range of severity in parent-child contact problem cases; natural affinity with the favoured parent, alignment with the favoured parent (arising from a loyalty conflict), realistic estrangement (often because of a rejected parent’s past abuse or poor parenting), and true alienation (where the estrangement from the rejected parent is unjustified). Even in the context of the latter, the severity of the alienation can range from mild to severe. Severe alienation (which often includes mental illness and/or personality disorders in the alienating parent) is seen when the alienating parent, “feeling above the law and with malice, deliberately fabricates or knowingly makes unfounded abuse allegations to intentionally discourage, interfere or prevent the child’s contact with the other parent.”: B.J. Fidler & P. Ward, “Clinical decision-making in parent-child contact problem cases: tailoring the intervention to the family’s needs”, in Abigail M. Judge & Robin M. Deutsch, Overcoming Parent-Child Contact Problems: Family-Based Interventions for Resistance, Rejection, and Alienation, (New York: Oxford Academic, 2017) (“Fidler & Ward, 2017”).

It is now widely acknowledged by researchers and academics that parent-child contact problems are best understood from a multi-factorial perspective. While there are cases in which a child’s rejection is totally the fault of one parent, in most cases both parents bear some responsibility for the estrangement and rejection.”

            Ginese v. Fadal, 2024 ONSC 2427 (CanLII) at 204-208

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