awarded sole custody to fathers based upon findings of PAS. In some cases a custody court's acceptance of allegations of parental alienation have resulted in children being placed in the custody of an abusive parent. The admissibility of testimony alleging PAS has been challenged under the Frye test and Daubert standard, to evaluate if it has sufficient scientific basis and acceptance within the scientific community. Richard Gardner's claims Although Gardner claimed that PAS was generally accepted by the scholarly community and had passed the Frye test in two states, a 2006 analysis of court cases involving PAS and cited by Gardner concluded that these decisions did not set legal precedent, that PAS is viewed negatively in most legal scholarship, and that Gardner's writings do not support the existence of PAS. Of sixty-four precedent-bearing cases reviewed at that time, only two decisions, both in New York State and both in criminal courts actually set precedents. Both held that the theory of PAS was inadmissible. One of the cases, subsequently upheld on appeal, found that PAS failed the Frye test as the appropriate professional community did not generally accept. At the time, Gardner listed fifty cases on his website that he claimed set precedents that made PAS admissible. Upon review it was determined that none of the cases set precedents for the admissibility of PAS. forty-six set no precedents or did not discuss admissibility and the remaining four were problematic. In the first the trial court found that PAS passed the Frye test, but that finding was not reviewed on appeal so as to become precedential as the trial court "[threw] out the words 'parental alienation syndrome'" and focused instead on the "willingness and ability of each parent to facilitate and encourage a close and continuing relationship between the parents and the child" under the state's child custody best interest factors. In the second case, the appellate court did not discuss PAS. The third case specifically chose not to discuss the admissibility of PAS and the fourth made no decision on PAS. Case law In one New York case, Matter of Robert Coull v. Pamela Rottman, 15 N.Y.S.3d 834, 131 AD 3d 964 (2015), child support was suspended based upon a trial court's finding of a parent's alienating behaviors. The court found that the father was prevented from seeing his son by the child's mother through a "pattern of alienation", and child