Oklahoma MCLE | Submitted for 1.0 OBA Ethics CLE Credit
Ethical Obligations of Attorneys Given Allegations of Parental Alienation
This CLE examines the professional responsibility obligations Oklahoma family law attorneys carry when parental alienation is alleged in a custody matter — covering competence under Baker’s Four-Factor Model, the Rule 3.1 threshold for meritorious claims, candor to the tribunal, and the critical intersection of PA allegations with domestic violence law under 43 O.S. §§ 111.3 and 111.4.
Presenter
Ron Gore, J.D.
Lewis & Gore PLLC
Credit
1.0 Hour — Ethics (MCLE)
Provider
Coparent Academy™
What You Will Learn
Apply Baker’s Four-Factor Model to distinguish alienation from realistic estrangement — and meet the Rule 1.1 competence baseline before filing or arguing PA
Evaluate whether a PA claim clears the Rule 3.1 threshold — documented, repeated conduct, not the client’s characterization alone
Navigate Rules 3.3 and 3.4 when expert conclusions outrun evidence, when a child’s preference appears coached, or when records are being withheld
Apply 43 O.S. §§ 111.3 and 111.4 — visitation enforcement remedies and the good-faith DV visitation refusal defense — to screen PA claims for DV context
Recognize potential DARVO litigation patterns (Deny, Attack, Reverse Victim and Offender) and assess their ethical implications for attorneys on both sides of a custody dispute
Analyze Hilfiger (2023), Jones (2018), Jensen (2015), and In re BTW (2010) — the current Oklahoma appellate landscape on PA in custody proceedings
Presentation Materials
Slide deck and Coparent Academy quick reference handouts.
CLE Slide Deck — Ethical Obligations of Attorneys Given Allegations of Parental Alienation
Full 36-slide presentation (PDF) | Oklahoma MCLE — Submitted for 1.0 Ethics Hour
Ethics Quick Reference Card Coparent Academy
OKRPC obligations, practice triggers, and red flags for PA matters — Rules 1.1, 1.3, 3.1, 3.3, 3.4, 3.5
Baker’s Parental Alienation Framework Reference Coparent Academy
Four-Factor Model, 8 Behavioral Manifestations (Gardner 1998; Baker 2018), and 17 Alienating Behaviors (Baker et al. 2011/2014)
Oklahoma Rules of Professional Conduct
Full text of each OKRPC rule addressed in this CLE — sourced from Okla. Stat. tit. 5, ch. 1, app. 3-A.
Oklahoma Statutes
Oklahoma Title 43 provisions directly applicable to parental alienation and custody matters — sourced from OSCN.
43 O.S. § 109 — Best Interests of the Child in Custody Determinations
Best interest factors, joint custody standards, parenting plan requirements, and § 109(I) DV rebuttable presumption — amended Laws 2024, SB 901
43 O.S. § 111.3 — Duty to Facilitate Visitation / Motion for Enforcement
21-day hearing / 45-day disposition; six-item remedies menu under § 111.3(D)(1)–(6); prevailing party attorney fees under § 111.3(E)
43 O.S. § 111.4 — Good-Faith Visitation Refusal When DV or Child Abuse Is at Issue
Statutory defense to visitation refusal; mandatory suspension when abuse is substantiated. Cited in Jones (2018) and Jensen v. Poindexter (2015 OK 49)
Power and Control Wheel
Duluth Model — identifying domestic violence control patterns as context for evaluating PA allegations
Oklahoma Case Law
Oklahoma appellate decisions addressed in this CLE — sourced from OSCN.
Hilfiger v. Hilfiger, 2023 OK CIV APP 15
Most recent Oklahoma PA holding — sole custody modification affirmed based on documented PA pattern
In re the Marriage of Jones, 2018 OK CIV APP 68
Reversed on OUCCJEA jurisdiction grounds — PA not adjudicated on the merits. Footnote 20 addresses the DV/PA intersection citing 43 O.S. § 111.4
In the Matter of BTW, 2010 OK 69
Oklahoma Supreme Court — treating psychologist declined to make PA determination; PA question unresolved at Supreme Court level
Christian v. Gray, 2003 OK 10
Oklahoma Supreme Court — Daubert/Kumho expert admissibility standards applicable to PA expert testimony in Oklahoma
Research & Academic Resources
Peer-reviewed sources referenced in this CLE and recommended for pre-seminar reading under the Rule 1.1 competence standard.
Baker, A.J.L. (2018) — Reliability and Validity of the Four-Factor Model of Parental Alienation
Journal of Family Therapy | doi: 10.1111/1467-6427.12253 | Foundation study for the Four-Factor Model framework
Harman, Kruk & Hines (2018) — Impact of Parental Alienating Behaviors on the Mental Health of Adults
Psychological Bulletin | Meta-analysis documenting psychological harm caused by PA behaviors
Meier, J.S. (2020) — Parental Alienating Behaviors as Domestic Violence
Journal of Social Welfare and Family Law | Critical analysis of PA claims in the context of domestic violence
Scientific Case Against Parental Alienation
Peer-reviewed critique of PA theory — cross-examination and Daubert/Kumho challenge resource | Full citation in slide deck
Scientific Status of Parental Alienation
Overview of current scientific consensus on PA — evidentiary foundation for qualifying and examining expert witnesses | Full citation in slide deck
Coparent Academy™ | CLE Ethics Program | Ron Gore, J.D. | Lewis & Gore PLLC
These materials are provided for educational and MCLE purposes only. Nothing in these materials constitutes legal advice. OKRPC text sourced from Okla. Stat. tit. 5, ch. 1, app. 3-A. Oklahoma statutes and case opinions sourced from OSCN. Academic materials provided under fair use for educational purposes.