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Domestic Violence in Child Custody Cases:

Increasing Safety and Wellbeing for All Family Members

The Institute of Continuing Legal Education July 13, 2010

Lore A. Rogers, Michigan Domestic Violence Prevention and Treatment Board

Daniel Saunders, University of Michigan School of Social Work

Rebecca Shiemke, Michigan Poverty Law Program

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Overview of Domestic Overview of Domestic ViolenceViolence

-Lore Rogers, Staff Attorney-Lore Rogers, Staff AttorneyMichigan Domestic Violence Prevention Michigan Domestic Violence Prevention

and Treatment Boardand Treatment Board

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Why Domestic Violence Is Relevant in Custody Disputes (Jaffe, P.G.

Lemon, N. & Poisson, S.E. (2002) Child Custody Disputes and Domestic Violence: Clinical and Legal Issues. Sage, Thousand Oaks, CA)

Abuse Does Not End With SeparationHalf of Abusers Likely to be Child Abusers Children Exposed to Abuse & Poor Role Model Undermining of Non-Abusive ParentNew Relationships Likely to be ViolentLengthy Litigation as Form of On-Going

Control & Harassment Higher Risk of Stalking & Homicides

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Reasons Why Focus Tends to be on Violence Against Women (Kimmel; 2002; (Kimmel; 2002;

Saunders, 2003)Saunders, 2003)

Some studies find men & women use force at approximately equal rates BUT:

Women tend to use violence in self-defense, especially for severe violence & homicide

Women are more severely injured physically & psychologically

Women are sexually assaulted & stalked at much higher rates

More difficult for women to leave

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Definitions of Domestic Violence: Definitions of Domestic Violence: Different definitions based on roles & settingDifferent definitions based on roles & setting

Social science: “Domestic violence” – use of physical force intended to physically harm. “Domestic abuse” includes physical abuse, verbal & symbolic behavior intended to harm

Criminal: “Domestic assault” is assault or assault & battery by current or former intimate partner or resident of household

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Definitions (cont.)Definitions (cont.)

Many practitioners: “Domestic violence” is a pattern of physical, emotional, sexual, and/or financial abuse meant to establish or maintain control in relationship (Michigan Batterer Intervention Standards) or “a pattern of coercive control”- Many call this “battering”, which seems

to fit one type of violence History: some of these terms have evolved

over time

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•Power & Control Wheel: Look for use of power and control tactics when exploring incident and history, and gently explore for detail

•“Has there ever been a time where you felt you had to use force with your partner?” Lore Rogers

•“Do you have any concerns about your own emotional and/or physical safety with the other parent?” Cook County Confidential Interview Questionnaire

IDENTIFYING DOMESTIC VIOLENCE

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•“How did you and your partner make decisions about your finances? About how you would raise your children?” Lore Rogers

•“Has your intimate partner ever forced you to do something you did not want to do?” ABA Tool for Attorneys to Screen for Domestic Violence, http://www.abanet.org/domviol/screeningtoolcdv.pdf

IDENTIFYING DOMESTIC VIOLENCE

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IDENTIFYING DOMESTIC VIOLENCE

An abuser can play the role of the victim, but does not know how to play the role of a survivor

Abuser wants you to sympathize with him or her in how badly s/he has it, because the partner is (pick one): a drinker, unfaithful, bad mother, poor housekeeper, unemployed and lazy, hard to live with, drug addict, unreasonable, a nag, etc.

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IDENTIFYING DOMESTIC VIOLENCE: DESCRIBE MEANINGFUL DETAIL

Does s/he provide an understandable description of incident with details?• chronological• makes sense• not missing significant pieces of time or event

Abusers won’t be able to do this – things just sort of “happen”

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IDENTIFYING DOMESTIC VIOLENCE: DESCRIBE MEANINGFUL DETAIL

Example: “We were in the bedroom, and she grabbed my keys from my pants pocket, ran to the bathroom. Then she came out of the bathroom, came at me, and we ended up on the floor.”

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IDENTIFYING DOMESTIC VIOLENCE: ACCOUNTABILITY AND BLAME

Abusers typically are not accountable for their behavior – it is someone else’s fault, usually their partner’s

Survivor/victim often expresses ambivalence about partner and/or partner’s behavior (“He’s not all bad.”)– Sometimes reluctant to limit or cut off partner’s

contact with children (and with herself)– Sometimes express belief that s/he deserved

partner’s abusive acts

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IDENTIFYING DOMESTIC VIOLENCE: ENTITLEMENT

Abuser’s sense of entitlement often will come through to set the rules for the other partner•to punish for breaking rules (“She knew she wasn’t supposed to do that”)•to retaliate•to be mad or hurt•to not have consequences for what happened (“Why did she have to bring the police into it?”)•To possess, isolate, have access to partner

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IDENTIFYING DOMESTIC VIOLENCE: FEAR

Saying one is or is not afraid of partner is not conclusive, but is an indicator

Abusers not afraid – are in control

 Survivor may say not afraid, won’t let him control her, but discussion reveals she alters behavior so as not to set him off

Abuser’s assertion that s/he’s afraid (a rare occurrence) won’t be supported by history

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Custody and Visitation: Custody and Visitation: Risk Factors and Safety Risk Factors and Safety

ConcernsConcerns

- Daniel Saunders- Daniel SaundersUniversity of Michigan School of Social University of Michigan School of Social

WorkWork

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Short-Term Impact of Domestic Violence on Children

Exposure to violence means SEEING or HEARING verbal or physical abuse or its AFTERMATH

Emotional & behavioral problems from exposure often include:– Nightmares, flashbacks, depression– Aggressive behavior– Academic problems– Teen substance abuse & truancy

Preschoolers at higher risk than older children Impact similar to being directly abused (Edleson, 1999; Graham-Bermann & Edleson, 2002; Kitzmann, Gaylord, Holt, &

Kenny, 2003; Wolfe, Crooks, McIntyre-Smith, & Jaffe, 2004).

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I hide under my bed when daddy hits mommy. I am scared. - “Jonathan”, age 5

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Children’s Reactions to FathersChildren’s Reactions to FathersChildren confused & ambivalent about

feelings toward their fathersSome express relief father is out of houseSome express sadness/longing Some children ally themselves with father and

see him as a victim, especially if they have seen him arrested.

Children may idealize fathers, especially if they have little contact with them. (Groves, et al., 2007)

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Excerpts from Teen’s LetterExcerpts from Teen’s Letter“The past couple of years have been hard on me. It has been

filled with many questions. I have been searching for answers to my questions. Why don’t my rights count? Why does the court not want to listen to me? Shouldn’t my right to be safe exceed my abusive father’s rights? . . . It made me so angry that I was being forced to visit my ‘‘father.” I hated him for what he has done to my family. He abused my brothers, my mother, and I. He didn’t just abuse us physically but mentally too. He would hurt us and make us feel like nothing. Yet, he had “Parental Rights’’ to us. . . . I have flashbacks of him on top of my brother smashing his head into the floor and my mother trying to stop it.” (Mich. Coalition Against DV Newsletter)

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Not All Children Not All Children Seriously Affected - Seriously Affected - Edleson, J.Edleson, J.

Over-generalizing about impact increases risk mothers are charged with failure to protect

On average children exposed show more problems than those not exposed

However, within the exposed group many children show no greater problems than comparison children - 50% in some samples

Protective factors in a child’s environment may prevent negative outcomes

Policies need to make distinctions to avoid universal “failure to protect charges”

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Post Separation Use of Children by Abusers (Lundy Bancroft)

Blaming his absence on mother/Using children to pressure her

Carrying messages (including encoded ones) to other parent

Exorbitant expenditures/promisesNot spending time with them or sporadic

visits

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Post Separation Use of Children By Abusers –2 (Lundy Bancroft)

Undermining her parentingTalking to children about changing custodyEncouraging them to disrespect herRetaliatory/intimidating custody and

visitation filings Filing retaliatory child abuse reports

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Post-separation Violence

Abuse, harassment & stalking continue at fairly high rates & may increase

Risk of homicide increases25% of women had lives threatened

during unsupervised visitation (Leighton, 1989)

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Impact of Violence on Victim’s Parenting

Survivors can be as nurturing as other parents BUT– From being abused many develop

depression, PTSD and other problems that MAY interfere with parenting (Jaffe & Crooks, 2005)

– Separation without abuse improves survivor and child’s well-being

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Mom’s Safety = Children’s SafetyMom’s Safety = Children’s Safety

Children’s safety is usually linked to their mother’s safety

Enhancing mother’s safety & stability is a major avenue for children’s well-being

Schechter & Edleson (1999) Center on Crime, Communities & Culture, Open Society Institute

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Women’s decision to leave or stay

Major reason for leaving: concerns over impact of violence on children AND

Major reasons for staying – concern for children: – Fear financial loss– Believe the children need their father– Fear she will lose custody to likely child abuser– Fear she & her children will be stalked, abused

and/or killed – Family pressures (Hardesty & Chung, 2006; Hardesty & Ganong, 2006).

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The Many Systems-Level The Many Systems-Level Traps for Survivors Traps for Survivors (Saunders, 2007)(Saunders, 2007)

A) If I stay, I could be accused of “failing to protect” my children from violence

B) If I leave quickly out of fear and do not bring my children, I will probably be accused of “abandoning” my children

C.1) If I leave with my children there is a good chance my ex will stalk, harass or abuse me and my children, and my ex will find ways to use the legal system to harass me

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C.2) If I leave & am reluctant to co-parent out of fear of past, present or future harm to myself or my child [e.g., if I want or need to relocate, keep my contact info confidential, insist on supervised visitation, am traumatized by the sight or voice of my ex] and/or

C.3) If I report his threats or violence toward myself or my children, then:

a) the "friendly parent" standard may be used against me, with the increased chance I will lose my children to the custody of an abuser and/or

b) I will be accused of making “false allegations” of abuse and/or

c) I will be labeled with “parent alienation syndrome”, with the increased chance that I will lose my children to the custody of an abuser.

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Failure to Detect or Document DVFailure to Detect or Document DV

Domestic violence often not detected or not documented in custody/visitation proceedings (Johnson, Saccuzzo & Koen, 2005; Kernic, Monary-Ernsdorff, Koepsell, & Holt, 2005).

– E.g., in study of documented abuse, there were frequent failures to consider documentation of domestic abuse and/or child abuse in the custody decision

(Silverman, Mesh, Cuthbert, Slote, & Bancroft, 2004).

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History of DV Has Little Impact on Court & History of DV Has Little Impact on Court & Mediator Decisions/RecommendationsMediator Decisions/Recommendations

Battered & non-battered women equally likely to be awarded custody;

Offenders and non-offenders are equally likely to be ordered to supervised visits (Kernic, Monary-Ernsdorff, Koepsell, & Holt, 2005; Silverman, Mesh, Cuthbert, Slote, & Bancroft, 2004).

Mediators about equally likely to recommend joint legal & physical custody for DV & non-DV cases

& rates of supervised & unsupervised visitation did not differ between violent and non-violent cases (Johnson et al., 2005)

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Beneath “High Conflict” CasesBeneath “High Conflict” Cases

High percentage of couples labeled “high conflict” are experiencing domestic violence (for review, see Jaffe & Crooks, 2007).

THUS it is essential to try to detect domestic violence within “high conflict” couples

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Common Custody Evaluation Errors (Lundy Bancroft)

Over-interpretation / mis-interpretation of psychological test data (e.g. MMPI) – not done in context of trauma history

Not understanding impact of domestic violence on mother's parenting

Misinterpretation of children’s behavior & statements – e.g. child’s identification with father’s power, divided loyalties, following

father’s lead in blaming mother

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Custody/Visitation Decisions: Abusers’ Advantages (Saunders, 2007)(Saunders, 2007)

Psychological traits: Men who batter tend to have chronic problems, but are skilled at hiding them

Survivors have more obvious trauma symptoms (PTSD, depression, “paranoia”) from– History of abuse in intimate relationship & often in

childhood– Separation violence– Fear of losing children to an abuser

Psychological tests & demeanor: survivor may appear “crazy” “overly-emotional” or flat affect, “hostile” “paranoid”, “borderline”

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Promising DevelopmentsPromising DevelopmentsIncreased domestic violence training for judges,

attorneys, evaluators and other professionalsExpansion of supervised visitation programs:

conditions can be ordered for abuser prior to or concurrent with visitation

Differential assessment & recommendations based on type and risk level of violence

“Fathering after violence” programs: Opportunities to engage offenders, heal effects of abuse, and decrease abuse of ex-partner

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Crafting Safe and Crafting Safe and Effective OrdersEffective Orders

-Rebecca Shiemke-Rebecca ShiemkeMichigan Poverty Law ProgramMichigan Poverty Law Program

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Domestic Violence & Child CustodyDomestic Violence & Child CustodyChild Custody Act MCLA 722.21 et seq.Child Custody Act MCLA 722.21 et seq.

Joint Custody: a court order that requires that a child reside alternately for specific periods with each of the parents, and/or that the parents share decision-making authority about important decisions affecting the welfare of the child.

Typically referred to as “physical custody” and “legal custody.”

MCLA 726a(7)

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Joint CustodyJoint Custody - - no statutory presumption, but is no statutory presumption, but is encouragedencouraged

Court must notify parties of it.Court must consider awarding joint custody

whenever requested by either parent.Court may consider joint custody when not

requested by either parent.If parties agree on it, court can only override

parties’ agreement on finding by clear and convincing evidence that it is not in the child’s best interests.

MCLA 726a(1)

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In deciding whether to order joint custody, Court must determine whether it is in the best interest of the child/ren and, in so doing, must: – Weigh the best interest factors in MCL

722.23, and– “Determine [w]hether the parents will be

able to cooperate and generally agree concerning important decisions affecting the welfare of the child.”

Joint CustodyJoint Custody [cont.-2][cont.-2]

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Promoting ChildPromoting Child’’s Best Interests in s Best Interests in Custody and Parenting Time DecisionsCustody and Parenting Time Decisions

Child Custody Act objectives:It is presumed to be in the best interests of a child

for the child to have a strong relationship with both of his or her parents. MCL 722.27a(1).

Each parent should facilitate and encourage a close and continuing parent-child relationship between the child and the other parent. MCL 722.23(j).

A child has a right to parenting time with a parent unless it is shown on the record by clear and convincing evidence that it would endanger the child's physical, mental, or emotional health. MCL 722.27a(3).

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The Challenge?Reconciling the mandates and policy

objectives of the Child Custody Act with the issues unique to cases where domestic violence has been, and often continues to be, a factor.

Safety of children and safety of abused parent both at issue.

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MichiganMichigan’’s Best Interest Factors for Custody Decisions s Best Interest Factors for Custody Decisions MCL MCL

722.23722.23 The sum total must be considered, evaluated and determined by the courtThe sum total must be considered, evaluated and determined by the court

A. Love, affection, other emotional ties existing between the parties involved & the child

B. Capacity, disposition of parties to give child love, affection & guidance, & to continue the education & raising of the child in his / her religion or creed

C. Capacity, disposition of parties to provide the child with food, clothing, medical care & other material needs.

D. Length of time child has lived in a stable, satisfactory environment, & desirability of maintaining continuity

E. Permanence, as a family unit, of the existing or proposed custodial home or homes

F. Moral fitness of the parties

G. Mental & physical health of the parties

H. Home, school, & community record of the child

I. Child’s reasonable preference, if the child is old enough to express one

J. Willingness/ability to facilitate, encourage the child’s close, continuing relationship with the other party

K. Domestic violence, regardless of whether directed against or witnessed by the child

L. Any other factor the court considers relevant in a particular case

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Determining CustodyDetermining Custody

When establishing custody:“Best interests of the child” govern. MCL

722.23.Courts must make specific findings on each

best interest factor. Overall v Overall, 203 Mich App 40 (1994).

Courts are not required to give equal weight to each factor. McCain v McCain, 229 Mich App 123 (1998).

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Best Interest Factors & Best Interest Factors & Domestic ViolenceDomestic Violence

Although domestic violence is only one factor, show how such conduct affects each factor.

Examples…

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Factor (b): capacity and disposition to Factor (b): capacity and disposition to give love, affection, guidancegive love, affection, guidance

Abusive behavior is not indicative of love and affection.

Abusive behavior is inappropriate role modeling.

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Factor (d): stable, satisfactory Factor (d): stable, satisfactory environmentenvironment

Lack of stability due to perpetrator’s use of violence.

Undesirable to continue abusive environment.

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Factor (f): moral fitnessFactor (f): moral fitness

Use of violence against family members is morally unfit.

Use of violence affects parental function.

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Factor (g): mental and physical healthFactor (g): mental and physical health

Survivor’s PTSD or depression from the abuse often affect ability to parent.

Abusers tend to have chronic psychological problems, but are skilled at hiding them.

Show that the survivor has sought appropriate treatment to limit affect of mental health on ability to parent.

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Survivors have a reasonable reluctance to co-parent out of fear of harm to themselves or their children.

Yet may end up being labeled "unfriendly," or “uncooperative.”

Thereby increasing the risk of losing their children if “friendly parent” standard weighted more heavily or domestic violence is discounted or undetected. (Saunders, 2007)

Factor (j): “friendly parent” standardFactor (j): “friendly parent” standard

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Factor (k): domestic violenceFactor (k): domestic violenceNeed not be “directed against or witnessed by

the child.”Evidence of pattern of abuse, threats &

violence.Abuser’s use of violence, fear and humiliation

actively interferes with continuity of a nurturing relationship between abused parent and child.

This directly and negatively impacts the child, even if the child has not directly witnessed abuse.

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Joint Custody & Joint Custody & Domestic ViolenceDomestic Violence

Is joint custody in the child’s best interests?

1. Joint custody is not supported by the sum total of the best interest factors. (See previous slides)

2. Most abusers are unwilling to “cooperate and generally agree” in joint decision making:

No equal bargaining power No interest in negotiating differences Cooperation provides continued contact and

opportunity for further abuse

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Why sole legal custody mattersWhy sole legal custody matters Generally, a parent “shall not change a legal

residence of the child to a location that is more than 100 miles from the child's legal residence.” MCL 722.31 (100-mile rule)

However -- The rule “does not apply if the order governing the

child's custody grants sole legal custody to 1 of the child's parents.” MCL 722.31(2)

An abused parent with sole legal custody need not seek court approval to move more than 100 miles within the state.

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Parenting Time &Parenting Time &Domestic ViolenceDomestic Violence

Safety concerns:– Access to victim and child– Opportunity for continued violence– Continued violence has negative effect

on child exposed– Exposes child to perpetrator’s subsequent

violent relationships

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Parenting Time OrdersParenting Time OrdersUse the statute:Frequency, duration and type (9 factors):

– Reasonable likelihood of abuse or neglect of child during parenting time.

– Reasonable likelihood of abuse of parent in the exercise of parenting time.

Specific termsReasonable terms or conditions that

facilitate orderly and meaningful exercise.MCL 722.27a(6), (7), (8)

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Orders...Orders...

Sample terms:– Avoid non-specific provisions –

“reasonable parenting time”“as agreed to by the parties”

– Instead, use specific terms –“the first and third weekend of every

month” “from Friday at 6:00 pm until Sunday

at 6:00 pm”

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Orders...Orders...Consider supervised parenting time:

– Supervised visitation center is preferred for the most severe cases.

– Otherwise, consider a professional, relative or friend.

– Order the abuser to pay any required fee– Consider batterer intervention treatment

during supervision.

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Orders...Orders...

Order can mandate interventions prior to or concurrent with supervised visitation or exchange:– Parent education groups– Fathering after violence programs– Substance abuse assessment and/or treatment– Abuser intervention programs

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Orders...Orders...

Consider tiered parenting time with interventions:

1.Supervised visitation center

2.Professionally-supervised off-site

3.Mutually acceptable lay supervisor

4.Brief unsupervised day visits

5.Longer unsupervised day visits

6.Overnights

7.Standardized parenting time

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Orders...Orders...

Specify pick-up and drop-off:– Supervised exchanges through a

supervised visitation center– Curb-side at parent’s home; do not exit

car– A neutral, protected location, such as a

police station or public place– By named third parties

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Orders...Orders...

Specify safe means to communicate:– Electronically – Through attorneys– Through a third party– Note: Be sure this provision doesn’t

conflict with provisions of any PPO

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Orders...Orders...Consider prohibitions/conditions:

– No alcohol before or during parenting time

– Limit access to firearms– No disparaging comments about other

parent– Successful completion of batterer

intervention program

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Orders...Orders...

Build in enforcement mechanisms:– Permit cancellation if parent fails to show

on time – Permit cancellation upon evidence of

violation of conditions– Require a bond to assure compliance

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Alternative Dispute Resolution/Mediation in Alternative Dispute Resolution/Mediation in Divorce & Custody CasesDivorce & Custody Cases

General advantages of ADR:

Faster Preserves financial

resources Preserves privacy Retains parties’ control Results in agreements

that may be more readily enforceable

Challenges with ADR in cases involving D.V:

Gives abusers access to survivors Gives abusers opportunities to

harass and intimidate survivors May require survivors to reveal

sensitive information Prerequisites for successful ADR

are generally lacking (imbalance in power, access to information)

Is likely to produce an agreement that does not attend to a survivor’s needs or concerns

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SCAO Mediation Screening Protocol

“When domestic violence is present, the case should be presumed inappropriate for mediation.”

However, the screening questions help to identify those cases with domestic violence that can mediate in a safe, fair and non coercive manner.

In such cases, the protocol also suggests appropriate safeguards.

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Thank you for your attention!!

Comments

&

questions are welcome!

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Additional Resources

Praxis International:

http://www.praxisinternational.org/

Family Violence Department, Nat’l Council of Juvenile & Family Court Judges: http://www.ncjfcj.org/dept/fvd/

Minnesota Program Development: The Duluth Model: http://www.duluth-model.org/

Leadership Council on Child Abuse & Interpersonal Violence: http://www.leadershipcouncil.org

MINCAVA Electronic Clearinghousehttp://www.mincava.umn.ed Minnesota Center Against

Violence & Abuse

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““Parent Alienation Syndrome”: 20 Year Parent Alienation Syndrome”: 20 Year Legal & Scientific Analysis Legal & Scientific Analysis JenniferJennifer Hoult, J.D., "The evidentiary admissibility of parental Hoult, J.D., "The evidentiary admissibility of parental alienation syndrome.”alienation syndrome.” Children's Legal Rights J. 2006.Children's Legal Rights J. 2006.

Precedent holds PAS inadmissible Most legal reviews are negative, e.g.

“diagnosis” of truth takes on role of fact finder Not scientifically reliable or validCircular reasoning: presumes pathology,

parental contribution & no justification Hoult counters claims of PAS originator

that 50 legal decisions & 23 peer reviewed articles support PAS

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PAS Criteria Ambiguous & Thus PAS Criteria Ambiguous & Thus Can Be Found in Following CasesCan Be Found in Following Cases

Severe child abuseAlienation caused by severe psychiatric

illnessNo contribution by “alienating” parent“Alienating” parent defends her legal rightsAdaptive or developmentally normative

alienationMutual parental denigration

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Dallam. S. J., & Silberg, J. L. (Jan/Feb 2006).Dallam. S. J., & Silberg, J. L. (Jan/Feb 2006). Methods for determining veracity of abuse

allegations are seriously biased in favor of alleged child molester when applying PAS

Paradox: The concerned custodial parent's attempts to obtain professional assistance protecting the child constitute evidence of "alienation”. Alienated parent’s behavior is not evaluated

Attorney Richard Ducote (2002) “ . . . the increased existence of valid evidence of true sexual abuse leads Gardner and his devotees to more fervently diagnose 'PAS.' Thus, 'PAS' is the criminal defense attorney's dream, since the greater the proof of the crime, the greater the proof of the defense."

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Multiple Reasons Multiple Reasons Children Reject ParentsChildren Reject Parents

A child's actual experiences of child abuse or lack of parental warmth from the rejected parent are as important as “alienating” behavior by other parent. (Johnston & Kelly, 2004)

Abuse – including bullying, humiliation & verbal assault Anger/hurt at parent’s decision & manner of divorce Worry/sympathy for left behind parent Loyalty conflicts Disruptions in school & peer activities Boredom when visiting a parent Jealousy & resentment about involvement of new partners

& step-siblings (Johnston, J. 2005)

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Prevalence Prevalence Non-lethal:

– 22% of women – 7% of men reported physical assaults by a current or

former spouse, cohabiting partner, boyfriend or girlfriend, or date in their lifetime (NVAWS Tjaden & Thoennes, 2000, nationally representative survey of 8,000 people)

Lethal:1,159 women murdered by intimates; 385 men murdered (2004, U.S. Department of Justice's Bureau of Justice)

Domestic Violence Offenses reported in Michigan in 2004: 72,796 men; 25,620 women (Uniform Crime Reports)