review panel and the Court of Appeal of England and Wales in the United Kingdom and Canada's Department of Justice recommends against its use. PAS has been mentioned in some family court cases in the United States. Gardner portrayed PAS as well accepted by the judiciary and having set a variety of precedents, but legal analysis of the actual cases indicates that as of 2006 this claim was incorrect. Exclusion from the DSM PAS is not included in the American Psychiatric Association's Diagnostic and Statistical Manual of Mental Disorders (DSM-IV). Gardner and others lobbied for its inclusion in the DSM-V revision. In 2001, Gardner argued that when the DSM-IV was released, there was insufficient research to include PAS, but since then, there have been enough scientific articles and attention to PAS that it merited being taken seriously. A survey of American custody evaluators, published in 2007, found that half of the respondents disagreed with its inclusion, while a third thought it should be. A related formulation, named parental alienation disorder, has been proposed, suggesting that inclusion of PAS in the DSM-5 would promote research and appropriate treatment, as well as reduce misuse of a valid and reliable construct. In December 2012, the American Psychiatric Association announced that PAS would not be included in the DSM-V revision. However, there are now diagnoses included in DSM-V that reflect the impact of parental behavior upon children, in particular parent-child relational problem and child affected by parental relationship distress. The key distinction is that the diagnoses listed in the DSM relate to the mental health of the diagnosed individual, as opposed to attempting to describe a disorder of the relationship between different people, whether parent-child or parent-parent. Scientific status Gardner's formulation of PAS is critiqued as lacking a scientific basis, and as a hypothesis whose proponents have failed to meet the scientific burden of proof to merit acceptance. The first publications about PAS were self-published and not peer reviewed, and though subsequent articles have been published in peer reviewed journals, most have consisted of anecdotal evidence in the form of case studies; in addition, the limited research into PAS has lacked evidence of its validity and reliability. The lack of objective research and replication, falsifiability, and independent publication has led to claims that PAS is pseudoscience or junk science. Proponents of PAS concur that large scale systematic controlled studies into PAS's validity and reliability