were not directly involved with families in custody disputes and that criticisms of this nature faded by the late 1980s because the disorder was widespread. However, no scientific study has yet demonstrated that the elements of PAS are unique to alleged parental alienation such that they are useful for diagnosis. PAS has been criticized by for being sexist, being used by fathers to marginalize legitimate fears and concerns about abuse, and women's groups and others oppose the legitimacy of PAS as a danger to children. After his initial publications, Gardner revised his theory to make fathers and mothers equally likely to alienate or be indoctrinators and disagreed that recognition of PAS is sexist. Gardner later indicated he believed men were equally likely to be PAS indoctrinators. Studies of children and adults labelled with PAS have suggested that mothers were more likely than fathers to be the alienator. In courts Canada Early Canadian court cases accepted expert opinions about PAS, used the term "syndrome" and concurred with Gardner's theory that only one parent was fully responsible for it. Gardner testified in one case (Fortin v. Major, 1996) but the court did not accept his opinion, concluding that the child was not alienated based on the evaluation of a court-appointed expert who, unlike Gardner, had met with the family members. More recent cases, while accepting the concept of alienation, have noted the lack of recognition in the DSM-IV, and have generally avoided "syndrome" terminology, emphasizing that changes in custody are stressful for the child and should only occur in the most severe cases. A 2006 research report by the Canadian Department of Justice described PAS as "empirically unsupported" and favored a different framework for dealing with issues of alienation that has more research support. Decisions about possible parental alienation are considered a legal decision, to be determined by the judge based on the facts of the case, rather than a diagnosis made by a mental health professional. There is recognition that rejection of a parent is a complex issue, and that a distinction must be made between pathological alienation and reasonable estrangement. United Kingdom In the United Kingdom, the admissibility concerning the evaluation of PAS was rejected both in an expert review, and by the Court of Appeal. United States On occasion, PAS has been cited as part of the child custody determination process in the United States, and some courts have