(Follower Submission): Theory of Resist–Refuse Dynamics (RRD) as Psychological Child Abuse (v1.0)

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Theory of Resist–Refuse Dynamics (RRD) as Psychological Child Abuse (v1.0)

Abstract

This document presents the theory that resist–refuse dynamics (RRD), when one parent

deliberately manipulates a child to reject the other fit parent without justification, constitutes a form

of psychological child abuse. Drawing from peer-reviewed research, amicus briefs, and therapeutic

frameworks, this paper outlines the profound short- and long-term harms to children, situates

resist–refuse dynamics (RRD) within existing child abuse diagnostic frameworks, and identifies

best-practice interventions.

Key Arguments

1. Induced Parent–Child Estrangement as Psychological Child

Abuse

Parental induced parent–child estrangement behaviors align with DSM-5 recognized categories

such as Parent–Child Relational Problem, Child Affected by Parental Relationship Distress, and

Child Psychological Abuse. Amicus briefs (Gottlieb, 2018) argue that induced parent–child

estrangement is equivalent in harm to other forms of abuse and should be treated as child

protection cases, not merely custody disputes.

2. Documented Psychological Harms

Systematic reviews (e.g., Miralles et al., 2021/23; Verrocchio et al., 2019) and qualitative studies

(Verhaar, 2022) show alienated children suffer elevated risks of depression, anxiety, low

self-esteem, insecure attachment, and substance abuse. They also experience identity disruption,

intergenerational transmission of induced parent–child estrangement, and in severe cases suicidal

ideation.

3. Induced Parent–Child Estrangement vs. Estrangement

Induced Parent–Child Estrangement must be distinguished from estrangement. Estrangement

occurs when rejection is justified by abuse or neglect. Induced Parent–Child Estrangement is

unjustified, externally induced rejection of a fit parent. Confusing the two leads to misdiagnosis,

further harm, and improper judicial remedies (Gottlieb, 2018).

4. Induced Parent–Child Estrangement and Adverse Childhood

Experiences (ACEs)

Induced Parent–Child Estrangement qualifies as an ACE, contributing to lifelong risks for mental

illness, substance use, and physical health problems. ACE research (Felitti et al., 1998; Anda et al.,

2006) shows childhood maltreatment, including psychological abuse, rewires brain development,

causing permanent harm.

5. Intervention Frameworks

Best practices include structured Reunification Therapy (RT) and Resist-Refuse Dynamic (RRD)

counseling. RRD supports children in overcoming induced rejection by focusing on coping skills,

critical thinking, and individuation from the favored parent. Crucially, therapy must avoid colluding

with favored parents’ abuse narratives, which risks reinforcing induced parent–child estrangement.

Constitutional Implications of ACE Integration

Recognizing Resist–Refuse Dynamics (RRD) within the ACE framework does more than establish

scientific credibility—it creates constitutional obligations. The State’s compelling interest in

protecting children from abuse is well established in child protection jurisprudence. Once RRD is

recognized as child psychological maltreatment equivalent in severity to other ACEs, the State

cannot selectively neglect it without violating both Equal Protection and Due Process principles. •

**Substantive Due Process**: As Troxel v. Granville and Parham v. J.R. confirm, fit parents hold a

fundamental right to direct the upbringing of their children. When courts permit or perpetuate RRD,

they infringe that right without satisfying strict scrutiny. No legitimate—let alone compelling—State

interest supports allowing one parent to deliberately destroy the child’s bond with the other fit

parent. • **Equal Protection**: ACE-informed frameworks protect children from physical and sexual

abuse, but courts often fail to treat RRD—an equally well-documented form of maltreatment—with

the same seriousness. This creates an irrational and discriminatory bifurcation, violating the

Fourteenth Amendment’s guarantee of equal protection of the laws. • **State’s Compelling

Interest**: Protecting children from adverse experiences is undeniably compelling. ACE science

demonstrates that failure to act exposes children to life-long risks of mental illness, substance

abuse, and even premature death. Once the State acknowledges this science, it must adopt

narrowly tailored remedies—such as mandated reunification therapy and restrictions on

interference—to fulfill its duty. Thus, integrating ACE findings into constitutional analysis

strengthens the case: the Court is presented with not only empirical evidence of harm, but also a

clear doctrinal basis for requiring heightened scrutiny and meaningful remedies when RRD

undermines both parental rights and child welfare.

Integration with Adverse Childhood Experiences (ACE)

Framework

The harms documented from Resist–Refuse Dynamics (RRD) align directly with the Adverse

Childhood Experiences (ACE) framework. ACE research, beginning with Felitti et al. (1998) and

reinforced by Anda et al. (2006), demonstrates that psychological abuse and household dysfunction

produce lasting neurological, psychological, and physical harms. Empirical studies of children

exposed to RRD confirm elevated risks of depression, anxiety, substance abuse, identity disruption,

and even suicidality, all of which mirror outcomes tracked in ACE studies. Further, intergenerational

transmission of induced estrangement echoes ACE findings that early adversity perpetuates cycles

of dysfunction across lifespans. By situating RRD within the ACE framework, courts are presented

with an established, peer-validated public health model: just as child physical or sexual abuse

compels intervention, so too must State actors respond to deliberate interference with a child’s

bond to a fit parent. Failure to intervene ignores settled science that psychological maltreatment

causes brain-level changes and long-term disease burden comparable to other ACE categories.

This integration strengthens the constitutional argument: the State not only undermines parental

rights by failing to act, it also fails its compelling interest in protecting children from abuse.

Supporting Evidence (Selected)

-Miralles, P. et al. (2021/2023). Systematic review of outcomes of resist–refuse dynamics (RRD).

Current Psychology.

-Verrocchio, M. C. et al. (2019). Parental induced parent–child estrangement and health-related

quality of life. Health and Quality of Life Outcomes.

-Verhaar, M., Matthewson, M., & Bentley, C. (2022). Adults’ experiences of resist–refuse dynamics

(RRD). Children.

-Ben-Ami, N., & Baker, A. J. (2012). The long-term correlates of childhood exposure to resist–refuse

dynamics (RRD). Am J Fam Ther.

-Felitti, V. J. et al. (1998). The ACE Study. Am J Prev Med.

-Anda, R. F. et al. (2006). Enduring effects of abuse and adversity. Eur Arch Psychiatry Clin

Neurosci.

-Gottlieb, L. J. (2018). Amicus Brief: Resist–Refuse Dynamics (RRD) as Psychological Child Abuse.

-Roles of a Child’s Individual Resist-Refuse Dynamic Counselor (RRD framework document).

Anticipated Critiques

- Some scholars argue that 'resist–refuse dynamics (RRD)' is not a formal DSM-5 diagnosis;
however, its behaviors clearly fit within existing abuse categories.
- Risk of misuse: allegations of induced parent–child estrangement may be weaponized in custody disputes. Safeguards are necessary to ensure induced parent–child estrangement is identified only when the rejected parent is demonstrably fit.
- Need for more longitudinal, population-based data to strengthen causal claims.

Open Questions

- What are the most effective, court-mandated intervention models for reducing induced
parent–child estrangement?
- How should courts distinguish rapidly between estrangement and
induced parent–child estrangement?
- Can policy reforms align custody law with clinical consensus
that induced parent–child estrangement constitutes abuse?

Legal scholarship notes an empirical turn in family law, where courts increasingly rely on social

science data. RRD theory is supported by systematic reviews and peer-reviewed studies

documenting harms equivalent to other forms of abuse. Presenting RRD as empirically grounded

assists courts in making fact-based decisions that respect constitutional parental rights.

3. Empirical Turn in Family Law

Parham recognizes a constitutional presumption that parents act in their child’s best interests.

Therefore, intervention in cases of alleged RRD should only be authorized upon compelling,

empirically supported evidence of psychological maltreatment and harm. This aligns RRD with

established due process protections.

2. Compelling Evidence Requirement (Parham v. J.R., 1979)

RRD represents interference with a child’s relationship with a fit parent, thereby undermining that

parent’s fundamental right to direct the upbringing of their child. As established in Troxel, courts

must give 'special weight' to a fit parent’s decisions. Judicial recognition of RRD ensures children’s

interests in a healthy parental bond are safeguarded without eroding parental authority.

1. Fundamental Parental Rights (Troxel v. Granville, 2000)

This section aligns the theory of Resist–Refuse Dynamics (RRD) as child psychological

maltreatment with the Supreme Court’s existing jurisprudence to enhance appeal viability.

Court-Oriented Arguments

Integration of Clinical Authority (Gottlieb Amicus Brief)

Linda J. Gottlieb’s amicus brief documents decades of clinical and forensic experience affirming

that interference with a child’s bond to a fit parent constitutes psychological child abuse. The brief

demonstrates that such conduct is documented in DSM-5 categories including Parent–Child

Relational Problem, Child Affected by Parental Relationship Distress, and Child Psychological

Abuse. Gottlieb highlights that uninfluenced children rarely reject a parent, even in cases of abuse,

underscoring that induced rejection is an externally manufactured pathology. Courts, she argues,

must treat these cases not as custody disputes but as child protection matters.

Integration of Therapeutic Framework (RRD Counselor Role)

The Roles of a Child’s Resist–Refuse Dynamic (RRD) Counselor document clarifies that RRD

therapy is designed to reduce unjustified resistance and facilitate reunification by strengthening

coping skills, identity development, and individuation from the favored parent. The framework warns

against granting children undue authority in determining contact schedules, recognizing that such

resistance is often induced. It further cautions against therapists colluding with favored parents’

'abuse narratives,' which perpetuates maltreatment and undermines the child’s best interests. This

clinical model demonstrates that effective intervention is possible, provided courts mandate

structured, role-appropriate therapeutic oversight.

Synthesis for Judicial Appeal

By combining the clinical authority established in Gottlieb’s amicus brief with the structured

interventions outlined in the RRD Counselor framework, courts can adopt an evidence-based,

constitutionally sound approach. This dual integration shows the Court that the issue is not

speculative—it is recognized by professional associations, validated by research, and treatable

through established therapeutic protocols. Presenting RRD as both constitutional (protecting

parental rights) and clinical (child protection from psychological abuse) makes the case compelling

for Justices across jurisprudential philosophies.

Chief Justice Roberts
As an institutionalist and minimalist, the Chief Justice is likely to favor a narrow, administrable rule.

Framing Resist–Refuse Dynamics (RRD) as a child psychological maltreatment case that requires

clear, empirically supported evidence before restricting a fit parent’s access aligns with his

preference for judicial modesty. This approach avoids sweeping pronouncements while ensuring

constitutional parental rights are respected.

Justice Thomas
Justice Thomas has consistently emphasized original meaning and strict scrutiny for fundamental

rights. In his Troxel concurrence, he argued that infringements on parental rights must meet strict

scrutiny. RRD should therefore be framed as a direct violation of fundamental parental rights that

requires the State to demonstrate a compelling interest and the least restrictive means, which it

cannot meet under current practices.

Justice Alito
Justice Alito values historical grounding and state primacy in family law. Arguments should stress

that recognizing RRD as child psychological maltreatment does not federalize custody law, but

enforces a constitutional floor that protects the fit parent–child bond. This respects federalism while

ensuring basic protections against unjustified interference.

Justice Gorsuch
Justice Gorsuch prioritizes textualism and due process protections. He is receptive to arguments

that emphasize the need for transparent procedures, notice, and opportunity to be heard before any

State interference in the parent–child relationship. RRD fits squarely within his due process

concerns.

Justice Kavanaugh
Justice Kavanaugh emphasizes administrability and workable tests. Framing RRD intervention as

requiring a neutral, empirically informed test—such as a clear evidentiary threshold plus

least-restrictive remedies—aligns with his preference for clear rules rooted in history and tradition.

Justice Barrett
Justice Barrett employs a Glucksberg-style history-and-tradition approach. Arguments should

emphasize that parental authority is deeply rooted in American tradition, and that interventions for

RRD must be narrowly tailored to address demonstrable psychological maltreatment without

undermining that tradition.

Justice Kagan
Justice Kagan values pragmatic solutions and administrable standards. She will be receptive to

arguments showing that recognizing RRD as maltreatment improves judicial accuracy, prevents

harm to children, and offers empirically supported, workable remedies without creating systemic

confusion.

Justice Sotomayor
J
ustice Sotomayor often highlights due process and equality, particularly for marginalized groups.

Arguments should stress how failure to address RRD disproportionately harms children and fit

parents—often fathers—who are denied equal protection. She is likely to respond to arguments

centering on fairness and the lived reality of harm.

Justice Jackson
Justice Jackson is attentive to text, fairness, and careful judicial reasoning. Arguments should

highlight statutory hooks, procedural safeguards, and a constrained constitutional rule that prevents

arbitrary interference while respecting the traditional role of States in family law.

Version Notes

v1.0 (Aug 2025): Initial draft integrating peer-reviewed research, amicus arguments, and RRD

framework.

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