Does the US Family Court System Recognize PAS as a Valid Argument?

The following excerpt from the National Council of Juvenile and Family Court Judges is used by PAS is a Scam to attempt to discredit the theory of PAS.

National Council of Juvenile and Family Court Judges. (2006).
Navigating Custody & Visitation Evaluations in Cases with Domestic Violence: A Judge’s Guide (2nd edition)

[excerpt]

“The discredited “diagnosis” of “PAS” (or allegation of “parental alienation”), quite apart from its scientific invalidity, inappropriately asks the court to assume that the children’s behaviors and attitudes toward the parent who claims to be “alienated” have no grounding in reality. It also diverts attention away from the behaviors of the abusive parent, who may have directly influenced the children’s responses by acting in violent, disrespectful, intimidating, humiliating and/or discrediting ways toward the children themselves, or the children’s other parent. The task for the court is to distinguish between situations in which children are critical of one parent because they have been inappropriately manipulated by the other (taking care not to rely solely on subtle indications), and situations in which children have their own legitimate grounds for criticism or fear of a parent, which will likely be the case when that parent has perpetrated domestic violence. Those grounds do not become less legitimate because the abused parent shares them, and seeks to advocate for the children by voicing their concerns.” – page 24

In this post’s biased attack on Dr. Warshak and the theory of PAS, the author fails to comprehend that this excerpt does not ‘prove’ Dr. Warshak wrong, but only drives home his own key points throughout his work on PAS, as I have understood them through reading his materials and corresponding with him. This excerpt also contradicts the author’s stance that the US family courts do not recognize alienation, regardless of the term used to describe it. This excerpt clearly states:

“The task for the courts is to distinguish between situations in which children are critical of one parent because they have been inappropriately manipulated by the other…”.

Although taken out of context, that single quote clearly shows that the court recognizes alienation is a valid possibility, although it uses the term ‘inappropriately manipulated’. While taking alienation into account as a possibility, as well as other possibilities that could be the cause of the deterioration between a child and parent such as abuse, the excerpt shows that the court sees it as a responsibility to determine which is the true cause of the deterioration of the parent/child relationship. This excerpt seems to mirror Dr. Warshak’s point of view:

"Naturally the labels PAS and PA do not ask the court to conclude that a child's alienation is unreasonable. They merely direct the court to an alternative explanation for why a child would want to erase a mother from her life. It is up to the court to decide which explanation best accounts for the problems in the family and, more to the point, whether it is in the child's best interest to repair a damaged relationship with the parent being rejected." - Dr. Warshak (email correspondence)

This excerpt seems to show the court’s careful stance on PAS, being cautious to not only not disallow valid accusations of abuse and mistreatment under a blanket term or diagnosis such as PAS, but also expressing the knowledge that alienation is a real problem that has enough merit to be carefully considered in a custody case, even if it’s defined by a different term in order to not be confused with the rejected term of PAS.