are required, supplementing a single small study in 2004 which suggested practitioners could come to a consensus based on written reports. The theoretical foundation of PAS has been described as incomplete, simplistic and erroneous for ignoring the multiple factors (including the behaviors of the child, parents and other family members) that may contribute to parental alienation, family dysfunction and a breakdown in attachment between a parent and a child. In this view, PAS confuses a child's developmental reaction to a divorce with psychosis, vastly overstates the number of false allegations of child sexual abuse, ignores the scientific literature suggesting most allegations of child sexual abuse are well founded and thus well-meaning efforts to protect a child from an abusive parent, exaggerates the damaging effects of parental alienation on children and proposes an unsupported and endangering remedy for PAS. Concern has been expressed that PAS lacks adequate scientific support to be considered a syndrome and that Gardner has promoted PAS as a syndrome based on a vague clustering of behaviors. Despite concerns about the validity of testimony regarding PAS, it has been inappropriately viewed as reliable by family court judges. Proponents of PAS and others agree that using the designation of syndrome may be inappropriate as it implies more scientific legitimacy than it currently deserves. While PAS is not accepted as scientifically valid, the concept of parental alienation has been advanced based upon theories of the "alienated child" and the dynamics that may have contributed to the child's alienation from a parent. Like PAS, parental alienation is not recognized as a diagnosable mental condition. Clinical status PAS has been criticized for making clinical work with children who are alienated more confusing and for labeling children with a mental diagnosis who may react angrily to their parents' separation or divorce. Gardner's analysis has been criticized for inappropriately assigning all responsibility of the child's behavior to one parent when the child's behavior is oftentimes, but not always, the result of a dynamic in which both parents and the child play a role. Gardner disagreed with criticism of PAS as overly simplistic, stating that while there are a wide variety of causes on why a child may become alienated from a parent, the primary etiological factor in cases of PAS is the brainwashing parent, and that otherwise, there is no PAS. Gardner also stated that those initially critical of PAS for being a caricature