36.1 INTRODUCTION
Society asks a great deal from Children’s Court judges. The community expects them to balance increasing legal complexities with frequently conflicting arguments about a child’s best interests. The court often weighs medical, psychological, and social information to produce decisions that are, at times, dissatisfactory to all the parties.

This chapter focuses on parents and four of the family-bound issues that can confront the Court: domestic violence, substance abuse, psychological dysfunction, and physical disabilities. The selection of these issues emerges from research over the last 20 years that has identified several core behaviors, attitudes, and attributes that relate strongly with positive child development.

This review makes several assumptions about parenting basics. Early emotional attachments between infants and their primary caretaker, usually the mother, have profound results on child functioning at subsequent developmental stages (Calkins & Fox, 1992; Greenberg, Speltz & DeKlyen, 1993). The sensitive attunement and accurate targeting in response to the infant’s cues form secure early attachments. Picking up on cues such as cry pitch, head turns, eye focus shifts, smiles, and frowns becomes difficult to impossible when the caretaker is impaired by domestic violence, mental illness, substance abuse, or certain physical or developmental disabilities (Susman-Stillman, Kalkoske, Egeland, & Waldman, 1996).

The child is the complementary player in this complex interaction. To respond to the cues of the parent, the child must be at ease and enjoy a sense of safety. Substance abuse, domestic violence, or mental illness can disrupt in this interaction and establish a negative pattern of attachment that carries into future adjustment and relationships.
At subsequent developmental stages, the parent needs to be there to provide structure, safety, support, limits, and guidance as the child explores the world and develops the cognitive structures and emotional regulation required for successful adaptation. Competent parenting demands sensitivity and responsiveness. Parents work with their children to develop self-efficacy and the sense of mastery. Healthy children with attentive caretakers learn how to minimize risk, solve problems, and diminish the effects of negative experiences.

It is not difficult to understand how domestic violence, substance abuse, mental illness, and some physical disabilities can limit these basic parenting competencies.

36.2 DOMESTIC VIOLENCE

36.2.1 DOMESTIC VIOLENCE AND CHILDREN
Five key issues emerge in the consideration of children exposed to domestic violence: child abuse, child observation of violence, child abduction, separation violence, and the trauma bond.

Child Abuse. Estimates differ, but at least half of all battering men also abuse their children (Pagelow, 1990). Child abuse increases and becomes more severe, as does the abuse of the battered partner (Bowker, Arbitel, & McFerron, 1988). When the wife is the victim, she is more likely to abuse her children than is the non-battered woman (Walker, 2000). The court should not hesitate to demand information about child abuse when domestic violence has been identified.

Child Observation of Violence. Most children – as many as 90% - in violent homes witness one parent battering the other (Pagelow, 1990; Walker, 2000). Bancroft & Silverman (2002) cite research to suggest that some fathers batter strategically in view of their children as a means of instilling fear and control. Children who have only witnessed violence are difficult to distinguish clinically from battered children. They are just as likely as battered children to present with physical and emotional symptoms such as eating and sleeping problems, depression, and anxiety (Jaffe, Wolfe, & Wilson, 1990).

Child Abduction. Batterers use custodial access to the children as a means to extend the physical violence and exert fear and control. Many victims flee with their children to escape the violence. Suits for custodial interference can be a tactic that the batterer uses after separation.

Separation Violence. More than 75% of the visits to emergency rooms by domestic violence victims occur after separation; half the homicides of battered women happened after divorce or separation (Walker, 2000). Leaving the battering partner does not stop the abuse. The court can play a special role in ensuring safety to the victim and the child following separation.

The Trauma Bond. A 15 year-old girl, missing from her Utah home for 9 months, is found with her abductors just a few miles from her neighborhood; the public asks why she did not run away or call the police. FBI hostage negotiators do not bargain with victims because of a phenomenon known as the Stockholm Syndrome, where the victim takes on the cause of the kidnapper. Freud (1979) identified identification with the aggressor as a way to explain why victims do not contest the harm done to them by the perpetrator. These are collectively and more accurately described as trauma bonds.

Domestic violence victims – partners and children – frequently harbor intense, ambivalent, and positive connections with their assailants. The Children’s Court judge cannot rely solely on the preferences children state when asked with whom they want to live. The assessment of a trauma bond can only be performed by a specially trained mental health professional. The court might consider such an assessment if: 1) the child exhibits physical or emotional symptoms of abuse without evidence against one of the parents; 2) the child has had repeated unsuccessful placements with one parent and still asks to return to that parent; or 3) if one parent maintains that only he or she can properly care for the child.

36.2.2 CUSTODY, VISITATION, AND PARENTAL RIGHTS
The child welfare system – and the courts - can have profound effects on children in families where there is domestic violence. The goal should be to make decisions based on current and adequate knowledge of the complex dynamics of domestic violence. This includes the special issues that battered parents and their children face. Such decisions may also take into account the unintended negative consequences that well meaning laws and child welfare stakeholders may bring with them.

Whether in an abuse or neglect case or in disputes between parents, there may be questions about the effect of domestic violence on custody and visitation. Many states have laws requiring that the court consider domestic violence when making child custody and visitation decisions. The American Bar Association (Davidson, 1994) urges the court to adopt a presumption against giving the child to the domestic violence perpetrator. The assumption here is that batterers frequently exhibit a pattern of control extending beyond the physical assault, and they may use the custody process itself to enforce control over their partners.

The potential dilemma for the court arises when the battering partner presents as more cooperative with a joint custody plan and the victim appears uncooperative. This occurs when the battered mother is trying everything to keep the children away from the abusive partner; she may present as “unreasonable” in her efforts. The court may want to consider exceptions to joint custody preferences for cases involving domestic violence. Similarly, the court needs to be aware of domestic violence control dynamics when the batterer instigates aggressive interstate custody litigation. The victim may flee the state with the child to avoid harm, and the batterer sues under a child kidnapping statute. These laws and the enforcing courts should consider exempting parents who flee in response to domestic violence.

The assumption, both in the law and in child welfare practice, is that the child benefits from ongoing contact with both parents. However, the court needs to consider the safety needs of both the battered parent and the child when setting up visitation orders. The court can order supervised visitation, when available. For the best interests of the child, the court can decide to deny visitation when it finds that a safe visit is not possible.

Another consideration to be addressed here is any proposed termination of the victim’s (usually the mother) parental rights because she failed to protect the child. In such cases, the court must fully investigate the true nature of the potential harm to the child. For example, exposure to domestic violence does not always constitute child abuse. Critical to such an investigation is the victim’s willingness and ability to prevent such exposure in the future. Once again, the court must make some difficult decisions based on the law and the information before it.

36.2.3 SUGGESTIONS FOR CONSIDERATION
Foremost in the mind of the court and the child welfare system should be the child’s immediate safety. Close in priority should be the treatment and recovery of the child victim. Treatment for victims and families, including the battering parent, can start once the safety issues have been addressed. The dynamics driving domestic violence are complex, and the strategies for helping the batterer must take into account the multi-determined forces that manifest in assaultive behavior. No one treatment approach can adequately explain or intervene successfully with all batterers.

The outcome research on the treatment of abusers is neither conclusive nor pessimistic. What has emerged consistently is that treatment can be successful, but it must include a comprehensive approach including careful assessment, individual and group therapy, and immediate response and consequences for recidivism. One of the most telling findings from abuser research is that outcomes improve in communities with a strong coordinated response. Abuser interventions appear to have cumulative effects. So, the offender who is arrested, prosecuted, put on probation, sentenced to community service, and ordered to therapy tends to have better treatment outcomes that the offender who is repeatedly warned, or just referred to therapy, or just put on a work detail (Green & Babcock, 2001).

36.3 SUBSTANCE ABUSE

36.3.1 CRITICAL FACTORS
Three critical factors come into play when the child welfare system and the children’s court face the issue of substance abusing caretakers. The first is the impact that drugs and alcohol have on the caretaker’s behavior. The second is the effect that drugs and alcohol have on the environment where parenting takes place. The third is the complex interaction between the caretaker’s own early history of abuse and neglect, and its cumulative negative results on parenting and caretaking behavior. These factors combine to produce impaired parenting and child maltreatment in most of the substance abusing families that come to the attention of the child welfare system (Grice et al., 1995). The more impairment in each of these areas that a caretaker brings to parenting, the more likely it is that the caretaker will abuse, and the more serious will be the impact on the developing child.

36.3.2 IMPACT OF SUBSTANCE ABUSE ON CARETAKER BEHAVIOR
An exhaustive review of current biological, chemical, and physiological studies on the results that alcohol and different drugs have on behavior is beyond the scope of this chapter. It is necessary to point out, though, that abusive use and dependence on alcohol and drugs usually cause impairments in the human organism that have concrete - and usually negative outcomes – on caretaking capacity. Alcohol and drugs take over the life of the substance abuser. The child’s needs for attention and nurturance quickly come second to the abuser’s need for the substance. Long term use results in mind and mood altering distortions in personality development. The abuser’s psychosocial development appears truncated to the observer, as if the addict stopped maturing while an adolescent.

People grow and develop in a complex interaction between their biology and their environment. The healthy development of cognitive schemas – the mental constructs that help us make sense of the world – requires flexibility and positive stimulation. The long term substance abuser has missed opportunities to incorporate information and experiences in a normative manner. Social relationships based on drug dealing and exploitation distort incoming information. The resulting self-absorption, distrust, and deception inhibit the growth of the healthy give and take characteristic of adaptive interpersonal interaction.

Substance abusers live chaotic and unpredictable lives. As parents, they are generally unable to bring structure, dependability, and consistency to caretaking. Absent, too, are the problem solving, stress management, and coping skills that effective parenting demands. As children, many adult substance abusers did not learn effective models for coping with life’s day-to-day stressors. The result is a parenting style marred by rigidity, inconsistency, harsh physical and verbal punishment, and emotional reactivity.

36.3.3 EFFECT ON THE SOCIAL ENVIRONMENT
Adaptive and healthy psychosocial functioning depends on the interaction of the child, the caretakers, and the social environment (Bronfenbrenner, 1979; Lerner, 1991; Sameroff, 1993). Substance abusing caretakers lead isolated lives, focused more on feeding the addiction than on nurturing the family. Substance abuse substantially diminishes the ability to establish and maintain even the most minimal relationship (Bell & Legow, 1996).

Isolation and poor social skills can lead to abuse and neglect (Gelles, 1989; Straus & Gelles, 1986). The isolated mother, poorly attached in her own right, seeks attention and nurturance from her child. When the child fails to satisfy the parent’s emotional needs, the reward is hostility, rejection, punishment, and the withdrawal of whatever meager emotional and physical caring had been available. This situation compounds the effects of poverty, especially when already limited resources are diverted to drug purchases, with the resultant increase in potential for child abuse and neglect, domestic violence, and parental mental illness (Kilpatrick, Acierno, Resnick, Saunders, & Best, 1997; Trickette, Aber, Carlson, & Cicchetti, 1991).

36.3.4 ABUSE AND NEGLECT SUFFERED BY SUBSTANCE ABUSER AS A CHILD
Depending on the study, upwards of 75% of substance abusing parents were abused, neglected, or sexually assaulted as children (Grice, Brady, Dunstan, Malcolm, & Kilpatrick, 1995). People who were sexually abused in childhood frequently develop symptoms of posttraumatic stress disorders (PTSD) along with patterns of substance abuse. Epstein, et al (1998) summarized the research pointing to substance abuse as self-medication to manage the PTSD effects. Interviews with over 3000 women found twice as many PTSD symptoms in subjects who reported child sexual abuse; also double was the incidence of alcohol abuse. Neglect experienced early in life along with physical and sexual abuse has been linked repeatedly to subsequent substance abuse in adult life (Boyd, 1993; Grice, et al, 1995; Pribor & Dinwiddie, 1992).

36.3.5 SUGGESTIONS FOR CONSIDERATION
This is the legacy of substance abuse, visited on generation after generation until the most effective set of interventions are applied. Without effective intervention, substance abuse and the resulting child maltreatment are likely to continue. All three factors have to be addressed: the impact on caretaker behavior, environmental effects, and the caretaker’s history of abuse and neglect. Interventions addressing only one of these factors are not likely to improve parenting.

When seen as the complex interaction of these three factors, the court can insist on the assessments and interventions that work. In relation to child welfare and Children’s Court issues, Drug Courts have shown some of the best outcomes. This is most likely due to their emphasis on coordinated approaches and immediate follow-up. As noted, single focused interventions seldom treat with the comprehensive attention needed to address this problem. Absent the availability of a Drug Court program, abusing parents who are substance abusers will require at least multifaceted interventions, case management, a progressive system of rewards, and immediate penalties.

36.4 MENTAL ILLNESS

36.4.1 EFFECT ON CARETAKING FUNCTION
Domestic violence and substance abuse frequently occur along with a range of diagnosable mental illnesses. In the child welfare system, however, the most critical aspect of a mental illness is the extent to which an individual’s illness or psychopathology interferes with the ability and capacity to parent. It is not the diagnosis or the kind of mental illness; it is the way that diagnosis presents itself in the care of the child. There is no one diagnosis that can be used to justify removal of a child or termination of someone’s parental rights. The key is how that caretaker’s illness manifests in basic social and caretaking functions. The goal is to provide for the child’s physical, emotional, and medical concerns.

There is no doubt that mental illness in parents and caretakers can represent a risk for the children in the family. It should also be noted that the children of the mentally ill have a higher risk for developing mental illnesses. When both parents are mentally ill, the chance is even greater that the child might become mentally ill (American Academy of Child & Adolescent Psychiatry, 1999). Genetic predispositions and high correlations between parent and child illness and have been identified with the following diagnoses: bi-polar disorder, attention deficit hyperactivity disorder (ADHD), schizophrenia, substance abuse, and depression.

The immediate impact on the child, though, is the often chaotic and unpredictable family environment that frequently accompanies psychiatric illness. A mentally ill parent or partner can put stress on the relationship and affect the parenting abilities of the couple. There is frequently confusion about family roles, with the children taking on many adult responsibilities, including the care of the mentally disabled parent. Poverty and limited access to resources make the situation even more difficult. The woman with serious mental illness is susceptible to multiple stressors that can complicate contraception, pregnancy, childbirth, and parenting.

36.4.2 SPECIAL CHALLENGES FACED BY THE PARENT IN TREATMENT
The parent with serious mental illness faces additional challenges in coming to grips with a child welfare or court-ordered treatment plan. The demands of obtaining treatment and supports for themselves and their children bring with them increased challenges and stresses. There may not be alternative childcare, and limited financial resources are now stretched to include additional transportation, missed work, the multiple demands of meeting the requirements of the treatment plan, and the fear that their life with their children may be coming to an end.

36.4.3 SUGGESTIONS FOR CONSIDERATION
It is critical for the court and the child welfare system to recognize the impact upon the child when the parent has a mental illness. This recognition encompasses the following needs that children in this situation present: mandatory reporting, accurate identification of the special issues involved, the response and interventions of the child welfare system, special protections and services for the child of the mentally ill parent, the nature of risk factors and protections for these children, and targeted services for the family and the child’s greater environment.

When making its determinations, the court and the child welfare system must look at a parent’s history, diagnosis, treatment compliance, and functioning level. This is an area where the overall child welfare system is comfortable and at least minimally resourced. It is within the capacity of most child welfare systems to order medical and psychological work-ups, home studies, individual and family therapy, case management, and follow-up.

There is, however, a frequently occurring emphasis on the concerns of the mentally ill parent. The chief concern must be the children and how they are affected. At the same time, the child welfare system can endorse the recovery attempts of the mentally ill parent. Recovery is based in mastery and empowerment. The child welfare system and the court can ensure that services and supports are in place to provide parents with information and tools to build their caretaking capacity.

36.5 PHYSICAL DISABILITIES

36.5.1 DISCRIMINATORY TREATMENT
Physical disabilities (e.g., a parent’s blindness or physical incapacitation) are frequently joined with cognitive or developmental disabilities in discussions about child welfare system interventions. Laws that prevent people with disabilities from serving as parents have long ago disappeared. For example, the state can no longer arbitrarily sterilize the developmentally disabled. Courts, in general, have determined that the right to marry, establish a home, and raise children is protected by the 5th and 14th amendments to the Constitution of the United States. Popular prejudice against people with disabilities as parents, however, has endured (Gilhool & Grand, 1985; Farber, 2000; Marshak, et al, 1999).

The following factors may influence the discriminatory treatment of physically and developmentally disabled parents:

• a presumption of inevitable neglect or abuse;
• a presumption that parenting deficiencies among the disabled are irremediable;
• a presumption that a parent’s deficiencies result from a disability rather than from poverty, poor housing, prejudice, social isolation, or the absence of support services;
• a presumption that the physically and developmentally disabled are equally handicapped in their ability to cope with the multitude of demands brought down upon them by the legal and social service system;
• the inadequacy of available legal services for the disabled parent facing removal of a child; or
• the perception that inter-dependent parenting is other then normal parenting. For example, if parental independence is the standard, the disabled parent who seeks help from a network and friends may be perceived as somehow inadequate.

The court and the child welfare system want to ensure that the disabled parent is not inadvertently subject to any prejudicial or discriminatory practices. Cases of child abuse or neglect requiring court intervention need to stand on their own merits, subject to the same standards that apply to similar situations where disability is not an issue. The child welfare system needs to be aware of negative community attitudes towards the disabled and examine closely allegations against the disabled parent. Child welfare professionals may need to examine their own attitudes and assumptions, and become advocates for the special needs that children with disabled parents may present.

The Americans with Disabilities Act may protect the disabled parent in the abuse or neglect proceedings to the extent that it requires the state to make reasonable accommodations so that services are available to that parent. See State ex rel. CYFD in the matter of John D., 1997-NMCA-019, 123 N.M. 114. The state should consider ways in which it can make accommodations to allow the parent’s full participation, for example, in the treatment plan

36.5.2 SUGGESTIONS FOR CONSIDERATION
In making child welfare determinations, a parent’s skills and abilities require assessment “in context.” Disabled parents live with social supports and social constraints; there is no “ideal” family. Finally, child welfare workers need to advocate with disabled parents to limit the fears among the disabled about system interventions such as the threat of child removal based solely on the disability.

From the court’s point of view, the mere presence of a disability should not be the sole determinant of an individual’s ability to function as an adequate parent. It might be helpful for the court to request an assessment of the areas of life affected by the disability, including housing issues, child care issues, respite, community resources and supports, transportation problems, and the availability of adaptive parenting equipment.

36.6 MAKING A COMPREHENSIVE ASSESSMENT
Parental ability to provide at least adequate care for children can clearly vary when the issues of domestic violence, substance abuse, mental illness, and physical and developmental disabilities enter the picture. For the children’s court judge and the child welfare system, the functioning level of the caretaker is the critical element in the determination of parental capacity. Regardless of level of stress or other environmental challenges, the emotional stability of the caretaker emerges in study after study as the most significant predictor of maltreatment (Berlin & Vondra, 1999; Egeland, et al, 2002; Pianta, et al, 1989).

The caution here is that no one condition and no stand-alone diagnosis should be the basis for a decision to disrupt a family. Final decisions about a parent’s ability and capacity to care for a child must attend to a comprehensive assessment of the caretaker’s levels of functioning, fitness to parent across more than one variable, the special needs of each child, the availability of resources, and the caretaker’s degree of compliance with court-ordered treatment plans.

36.7 REFERENCES

• American Academy of Child & Adolescent Psychiatry. (1999). Children of parents with mental illness. Washington, DC: AACAP.
• Bancroft, L., & Silverman, J.G. (2002). The Batterer as parent: Addressing the impact of domestic violence on family dynamics. Newbury Park, CA: sage.
• Bell, S.A., & Legow, N.E. (1996). Attachment theory as a working model for the therapist transitioning from early to later recovery substance abuse treatment. American Journal of Drug and Alcohol Abuse, 22 (4), 533-547.
• Belle, D. (1990). Poverty and women’s mental health. American Psychologist, 45 (3), 385-389.
• Berlin, P.M. & Vondra, J.I. (1999). Psychological maltreatment of children. In R.T. Ammerman & M. Hersen (Eds.), Assessment of family violence: A clinical and legal sourcebook (2nd Edition). New York: John Wiley.
• Bowker, L.H., Arbitel, M., & McFerron, J.R. (1988). On the relationship between wife beating and child abuse. In K Yllo and M Bograd (Eds). Perspectives on wife abuse. Newbury Park, CA: Sage.
• Boyd, C.J. (1993). The antecedents of women’s crack cocaine abuse: Family substance abuse, sexual abuse, depression, and illicit drug use. Journal of Substance Abuse Treatment, 10, 433-438.
• Bronfenbrenner, U. (1979). The ecology of human development: Experiments by nature and design. Cambridge, MA: Harvard University Press.
• Calkins, S.D., & Fox, N.A. (1992). The relations among infant temperament, security of attachment, and behavioral inhibition at twenty-four months. Child Development, 63, 1456-1472.
• Davidson, H. (1994).The impact of domestic violence on children: A report to the president of the American Bar Association. Washington, DC: American Bar Association.
• Egeland, B., Bosque, M., & Levy, A.K. (2002). Continuities and discontinuities in the intergenerational transmission of child maltreatment: Implications for breaking the cycle of abuse. In K. Browne, H. Hanks, P. Stratton, & Chameleon (Eds.), The prediction and prevention of child abuse: A handbook (pp.217-232). New York: John Wiley & Sons.
• Epstein, J.N., Saunders, B.E., Kilpatrick, D.G., & Resnick, H.S. (1998). PTSD as a mediator between childhood rape and alcohol use in adult women. Child Abuse & Neglect, 22 (3), 223-234.
• Farber, R.S. (2000). Mothers with disabilities: In their own Voice. American Journal of Occupational Therapy, 54, 260-268.
• Freud, A. (1979). The ego and the mechanisms of defense (revised edition). Cambridge, UK: International Universities Press.
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• Gilhool, T.K. & Gran, J.A. (1985). Legal right of disabled parents. In S.K. Thurman (Ed.), Children of handicapped parents. Orlando, Florida: Academic Press.
• Green, C., & Babcock, J. (2001). Does batterers’ treatment work? A meta-analytic review of domestic violence treatment. Proceedings, 7th International Family Violence Research Conference. Portsmouth, New Hampshire.
• Greenberg, M.T., Speltz, M.L., & DeKlyen, M. (1993). The role of attachment in the early development of disruptive behavior problems. Development and Psychopathology, 5, 191-213.
• Grice, D.E., Brady, K.T., Dunstan, L.R., Malcolm, R., & Kilpatricj, D.G. (1995). Sexual and physical abuse history and post traumatic stress disorder in substance dependent individuals. American Journal of Addictions, 4, 297-305.
• Jaffe, P., Wolfe, D.W., & Wilson, S. (1990). Children of battered women: Issues in child develop and intervention planning. Newbury Park, CA: Sage.
• Kilpatrick, D.G., Acheron, R., Resnick, H.S., Saunders, B.E., and Best, C.L. A 2-year longitudinal analysis of the relationships between violent assault and substance use in women. Journal of Consulting & Clinical Psychology, 65 (5): 834-47.
• Lerner, R.M. (1991). Changing organism-context relations as the basic process of development: A developmental contextual perspective. Developmental Psychology, 27 (1), 27-32.
• Marshal, L.E., Seligman, M., & Prezant, F. (1999). Disability and the family life cycle. New York, NY: Basic Books.
• Pagelow, M. (1990). Effects of domestic violence on children and their consequences for custody and visitation agreements. Mediation Quarterly, 7, #4. pp 45-53.
• Pianta, R., Egeland, B., & Erickson, M.F. (1989). The antecedents of maltreatment: Results of the mother-child interaction project. In D.Cicchetti and V. Carlson (Eds.), Child Maltreatment. Cambridge: Cambridge University Press.
• Pribor, E.F., & Dinwiddie, S.H. (1992). Psychiatric correlates of incest in childhood. American Journal of Psychiatry, 149 (1), 52-56.
• Sameroff, A.J. (1993). Models of development and developmental risk. In C.H. Zeanah, Jr. (Ed.), Handbook of infant mental health (pp.3-13). New York: Guilford.
• Strauss, M.A., & Gelles, R.J. (1986). Societal change and change in family violence from 1975 to 1985 as revealed in two national surveys. Journal of Marriage and the Family, 48, 465-479.
• Susman-Stillman, A., Kalkoske, M., Egeland, B., & Waldman, I. (1996). Infant tempermant and maternal sensitivity as predictors of attachment security. Infant Behavior and Development, 19, 33-47.
• Trickett, P.K., Aber, J.L., Carlson, V., & Cicchetti, D. (1991). Relationship of socioeconomic status to the etiology and developmental sequelae of physical child abuse. Developmental Psychology, 22 (1), 148-158.
• Walker, L.E. (2000). The battered woman syndrome (2nd edition). NYC: Springer Publishing Company.
  

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