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DARVO in the Courtroom: How Narcissistic Abuse Patterns Play Out in Custody Litigation

February 25, 2025 | By Dr. Kristin M. Tolbert, Psy.D.

DARVO stands for Deny, Attack, Reverse Victim and Offender. It was first described by psychologist Jennifer Freyd in 1997 to explain a pattern observed in people confronted with their harmful behavior. Rather than acknowledging what happened, they denied it, attacked the person raising the concern, and repositioned themselves as the real victim.

In family court, this pattern is common enough that attorneys and judges who work in high-conflict custody cases often recognize it informally. The challenge is that recognizing it informally is not the same as being able to identify it in the record and explain it to a court in a way that holds up.

What it looks like in litigation.

A parent raises a legitimate concern about the children's safety or welfare. The response is not to address the concern. The response is a counter-allegation: the concerned parent is controlling, unstable, alienating, or fabricating. The original concern gets buried under the counter-narrative, and the parent who raised it finds themselves defending their own conduct instead of advocating for their child.

In documentation, DARVO often looks like this: every protective action the targeted parent takes gets characterized as aggressive or manipulative. Keeping records becomes harassment. Requesting a custody evaluation becomes an attack. Reporting a safety concern becomes a campaign to undermine the other parent. The targeted parent's behavior is described in the most pathological available terms while the same behavior in the other parent is described neutrally or not described at all.

Why it is effective in court.

DARVO works partly because courts are designed to hear both sides. When one parent says the other is harming the children, and the accused parent responds by saying the first parent is actually the problem, a court without psychological context may treat this as a dispute requiring more investigation. The abuse pattern effectively produces its own cover.

It also works because the targets of this kind of conduct often present poorly in court. They are exhausted, they may appear reactive or hyperfocused on the other parent's behavior, and they have usually spent years in a dynamic designed to destabilize them. That presentation can be misread as the problem rather than as the result of the problem.

What this means for custody evaluations.

A custody evaluator who identifies a DARVO pattern in their analysis needs to document it carefully and ground it in the behavioral record. An evaluator who does not understand the pattern may inadvertently reproduce it by pathologizing one parent's protective behavior while treating the other parent's counter-allegations at face value.

The APA Guidelines for Child Custody Evaluations (2022) require evaluators to investigate the basis for each parent's concerns and to avoid assumptions about which parent's narrative is more credible without supporting data. An evaluation that describes one parent's documentation as a relentless campaign while treating the other parent's lack of documentation neutrally has not met that standard.

For attorneys and parents.

If DARVO is present in a case, it needs to be named, explained, and supported with specific behavioral examples. Saying someone is narcissistic is not useful in court. Showing the court a documented, consistent pattern of deny-attack-reverse, drawn from communications, testimony, and the factual record, is a different matter entirely.

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