I raised the standing 990‑N item at the end of this report (one line, not part of the article). Now the investigation.

Four Years, Zero Dollars: Congress Passed Kayden's Law in 2022 — Then Never Funded It, Never Measured It, and Never Told Anyone Which States Complied

In March 2022, Congress wrote into federal law an explicit finding that American family courts believed only 1 out of 51 claims that a father had sexually molested a child when the father countered with an accusation of "parental alienation," that roughly one-third of parents accused of child abuse won primary custody from the parent who reported it, and that nearly 800 children had been murdered by a divorcing or separating parent since 2008 — more than 100 of them after a court ordered the contact over a safe parent's objection. Congress then created a financial incentive to fix it: the Keeping Children Safe from Family Violence Act, "Kayden's Law," which promised states up to a 10 percent bump in their federal STOP domestic-violence grant if they restricted junk-science expert testimony, banned court-ordered "reunification treatment" that lacks scientific proof of safety, and mandated 20 hours of trauma training for every judge and custody evaluator who touches a custody docket. Four fiscal years later, a Congressional Research Service audit of every Justice Department grant program shows the appropriation line for Kayden's Law reading the same thing every single year: an em dash. Zero dollars. The Office on Violence Against Women has never mentioned the provision in a STOP solicitation, has never published which states qualify, and — because Congress wrote no reporting requirement into the statute — was never required to.

How the Machine Actually Works

The provision is codified at 34 U.S.C. § 10446(k), added by Public Law 117-103, Division W, Title XV, §§ 1501–1504 (136 Stat. 951–956). Its architecture is conditional-spending federalism: the Attorney General "shall increase" a state's STOP formula grant by "not more than 10 percent of the average of the total amount of funding provided to the State … under the 3 most recent awards," for one fiscal year at a time, renewable, capped at four fiscal years total.

To be an "eligible State," a state must have all of the following in effect simultaneously:

• § 10446(k)(3)(A) — a law limiting expert evidence in custody cases involving abuse allegations to professionals with "demonstrated expertise and clinical experience in working with victims of domestic violence or child abuse … that is not solely of a forensic nature," and requiring courts to weigh past protection orders, arrests, and convictions.
• § 10446(k)(3)(B) — five hard prohibitions, including that a court "may not order a reunification treatment, unless there is generally accepted and scientifically valid proof of the safety, effectiveness, and therapeutic value of the reunification treatment," and "may not order a reunification treatment that is predicated on cutting off a child from a parent with whom the child is bonded."
• § 10446(k)(3)(C) — not less than 20 hours of initial training and 15 hours every five years thereafter for judges, magistrates, guardians ad litem, best-interest attorneys, counsel for children, custody evaluators, masters, and mediators.
• § 10446(k)(4) — uniform standards for any court-appointed "neutral professional" opining on abuse or trauma.
• § 10446(k)(5) — a training program that "does not include theories, concepts, or belief systems unsupported by" evidence-based, peer-reviewed research.

That last clause is the sharpest instrument in the statute. It is a direct legislative strike at parental alienation theory. And it has never been enforced against a single state, because the enforcement mechanism was money that never arrived.

The Money: $5 Million Authorized, $0 Appropriated, $91 Million Sitting Idle

Section 1504 authorized $5,000,000 for each of fiscal years 2023 through 2027. Authorization is permission to spend; appropriation is the money. CRS Report R48898 (March 27, 2026), a comprehensive inventory of DOJ grant authorizations and appropriations, lists "Keeping Children Safe From Family Violence Act or Kayden's Law (34 U.S.C. §10446(k))" with an appropriation of "—" for FY2017 through FY2026. CRS defines that symbol precisely: "an em dash (—) indicates that appropriations were not provided for that fiscal year."

The contrast with the program it was bolted onto is stark. OVW's FY2025 STOP Formula Grant Program solicitation lists an expected total of $171,206,049, with individual state awards ranging from $617,851 to $16,188,360 and a $600,000 base for every state and territory. The DOJ Inspector General's Audit Report 26-061 (June 2026) found that STOP grew from roughly $140 million in 2022 to $173 million in 2023, that OVW awarded more than $773 million in STOP funds across FY2020–FY2025, and that as of December 31, 2025 states had left more than $91 million of STOP and SASP money unspent. The OIG's own subtitle: "OVW Should Work to Remedy over $23 Million in STOP and [SASP funds]." The audit found unclosed grants exceeding $66 million — and reported that of the nearly $176 million awarded for FY2025 STOP, states had spent less than 2 percent by the end of 2025.

So the accounting is this: nearly $100 million in domestic-violence money is sitting unspent in state accounts, and the one line item Congress created specifically to make family courts stop handing children to people it had found to be abusers received nothing.

Nor did OVW use its discretionary authority to fill the gap. A keyword search of the FY2024 and FY2025 STOP Formula solicitations returns zero occurrences of "Kayden," "§ 10446(k)," "grant increase," "reunification," or "child custody proceeding." The related Justice for Families Program (34 U.S.C. § 12464), authorized at $22 million annually, was funded at an expected $14,000,000 in FY2025 — and its solicitation is also silent on Kayden's Law. Section 12464(d)(7) does require that custody evaluators and guardians ad litem paid with those funds be trained on "the use of evidenced-based theories to make recommendations on custody and visitation," but that binds only grantees, not courts.

There is one more structural fact, and it is the load-bearing one: the statute contains no reporting requirement. Sections 1501–1504 direct no annual publication of qualifying states, commission no GAO study, and require no data collection on children harmed or killed during court-ordered contact. The DOJ Inspector General's 2026 STOP audit does not mention Kayden's Law once. Congress built an incentive with no scoreboard, then declined to pay the prize.

The Industry the Statute Was Written to Stop

The reunification sector operates in a regulatory seam. Programs are typically for-profit LLCs or sole proprietorships. They are not licensed as residential child-care facilities, not licensed as child-placing agencies, not billed through insurance (so no utilization review), and frequently operated by people who hold no clinical license in the state where the child is delivered. Their revenue comes from parents ordered to pay, under threat of contempt.

Randy Rand, the psychologist who developed Family Bridges, was disciplined by the California Board of Psychology in 2009 (Case No. 1F 2004 158933) for an "extreme departure from the standard of practice" after testifying in family court that a child was severely alienated and should attend his own program — without ever having met the child. He was placed on probation and barred from practicing. In 2019, the Board cited him for violating probation (Citation No. 600 2019 000149) and he was permanently suspended. Family Bridges continued.

Craig Childress, whose diagnostic framework Nevada legislators heard described in sworn testimony as "the work of a quack," was found by the Oregon Board of Psychology (Final Order, Case No. 2020-001) to have engaged in the unlicensed practice of psychology in violation of ORS 675.020(1) and fined $7,500. The record shows he charged $500 per consultation report, with additional fees to testify.

Rebecca Bailey's Transitioning Families, an equine-based California program, was the subject of appellate litigation in which a court described Bailey as "eminent" without identifying the field. A survivor testified she was pulled from school and held incommunicado for more than ten months under a family court order, told she was "delusional," and pressed to disbelieve her own memories of her mother. Her family's bill: $214,000.

Linda Gottlieb's Turning Points for Families, based in New York and operating a Texas arm, has been the subject of ProPublica reporting since 2023, including cases in Utah where siblings livestreamed their court-ordered removal on TikTok. An NBC Bay Area investigation documented a single workshop billed at nearly $40,000, including hotel and transport.

The referral loop is the conflict of interest. In In re Harris (Cal. Ct. App. 2014), a family court had already found — by a preponderance, after a full evidentiary hearing — that the father sexually abused the child, and had awarded the mother sole custody with no visitation. A successor judge appointed Amy Stark, a for-profit consultant with no specialized child-sexual-abuse expertise, as "case manager" for a "supervised reunification process." Stark then recommended a reunification therapist. The expert who diagnoses the problem recommends the program; the program bills the family; the same expert returns to court to report progress. No state licensing board sits anywhere in that circuit.

The scientific ground has meanwhile shifted underneath the entire enterprise. The UN Office of the High Commissioner for Human Rights concluded that "parental alienation" lacks "a universal clinical or scientific definition" and "has become a tool for denial of domestic and child abuse." The Oregon Board of Psychology found in a separate matter that a psychologist violated her professional duty by treating parental alienation "as if it were a diagnosis" — "not possible to diagnose," the Board wrote, because it appears nowhere in the DSM-5 — and that her referral of children to a four-day distance workshop "constituted a danger to the children's emotional health or safety." A critical review published in January 2026 is titled, flatly, The Scientific Case Against Parental Alienation.

What It Looks Like From Inside

On May 28, 2025, the Nevada Assembly Judiciary Committee took testimony on Senate Bill 275 — the state's Kayden's Law bill, sponsored by Senator Nicole Cannizzaro. Three witnesses described the same case.

Hannah Vahey testified that after she and her siblings resisted returning to their father's home, the violence escalated; that in fall 2021 her father strangled her brother Matthew when Matthew intervened; that her psychiatrist saw the bruises and reported him to CPS — not for the first time. "Instead of believing us and protecting us, the judge blamed our mother," she testified. "The judge accused my mother of parental alienation and forced us into reunification camp on the other side of the country. Kayden's Law was passed in March of 2022, but it was not soon enough to save us because our state had not yet adopted Kayden's Law."

They were taken to New York on April 8, 2022. Hannah testified that Linda Gottlieb assaulted her, that she was locked in a hotel room with the father, and that she was hospitalized for 72 hours in a children's psychiatric ward. A retired anesthesiologist, Kim Chen, corroborated the timeline from outside: the handoff, the message from Matthew that Hannah had been punched, the police and paramedics at the hotel room. Hannah later ran away, carrying a recording her father had made of himself abusing them. The judge would not admit it. Only an appeal returned the children to their mother.

Selena Vahey, eleven years old, described the recurring nightmare she has had for four years — separate dark cages, Gottlieb walking between them — and testified that after she first spoke to legislators in Carson City in April, "Linda Gottlieb contacted my father and suggested we do another round."

Marshal Willick, a 40-year Nevada family law practitioner and American Academy of Matrimonial Lawyers fellow who has litigated roughly a dozen of these cases, told the committee the practice "is designed to reunify a child with an estranged parent by breaking the child's will and spirit… systematized brainwashing intended specifically to cause Stockholm syndrome… We do not let prisons do to inmates what is being done to these children."

Nevada's governor signed SB 275 in June 2025.

The Body Count Nobody Federal Is Counting

The children whose names are on these statutes died in court-supervised arrangements. Kayden Mancuso, 7, of Bucks County, Pennsylvania, was beaten to death by her father during court-ordered unsupervised parenting time in 2018; her mother, Kathryn Sherlock, had already put his criminal record and a protection order for threatening to kill family members in front of the court, and a professional had recommended mental-health treatment as a precondition. Kyra Franchetti, 2, was shot in her sleep during court-ordered unsupervised visitation in New York. Aramazd "Piqui" Andressian Jr., 5, in California. Greyson Kessler, 4, in Florida in 2021. Om Moses Gandhi, 16, in Utah. In 2024, Alec Mater, 7, and his sister Lydia, 6, were killed by their father during court-ordered parenting time in Arizona after their mother, Hope Hooton, got fifteen minutes in front of a judge to argue against it.

The result is a national legislative tradition built out of dead children: Kayden's Law (PA Act 8 of 2024), Kyra's Law (NY, passed the Assembly June 8, 2026), Piqui's Law (CA SB 331, 2023), Greyson's Law (FL HB 97, 2023), Om's Law (UT HB 272, 2024), Colorado HB24-1350, Arizona SB 1372, Nevada SB 275 (2025), and the still-pending Alec and Lydia Act (AZ HB 2995). Every one is partial. Several capture the reunification ban but not the 20-hour training mandate; others do the training but leave expert-witness qualification untouched. Because § 10446(k) requires all elements at once, patchwork adoption produces no eligible states — and since no money was ever appropriated, no one at DOJ has had occasion to say so out loud.

There is no federal count of children killed during court-ordered contact. The only national tally is maintained by the Center for Judicial Excellence, a small nonprofit in San Rafael, California, which tracks cases by reading news coverage and now lists more than 980 child murder victims since 2008, updated weekly. Congress cited an earlier version of that volunteer database — "nearly 800 child murders" — as the factual predicate for a federal statute. Four years later, that same volunteer database is still the best number the United States has.

The Accountability Gap

Five separate watchdogs are structurally excused from watching. OVW has no statutory duty to publish which states qualify and no appropriation to administer. The DOJ Inspector General audited $773 million in STOP funds in June 2026 without a single reference to the incentive attached to them. GAO was never tasked. State administrative offices of the courts control judicial training curricula and answer to state supreme courts, not to DOJ. And litigants have no remedy: § 10446(k) creates no private right of action, and judicial immunity forecloses damages against the judge who signs the order.

Meanwhile the underlying research keeps pointing the same direction. Joan Meier's GWU study — a review of more than 2,000 published opinions over 15 years — found that a father's cross-claim of parental alienation virtually doubles courts' rejection of a mother's abuse allegations and her loss of custody, and that appointing a guardian ad litem or custody evaluator intensifies that skepticism toward mothers specifically. Washington State's Crime Victim Services Work Group repeated those findings to the state Supreme Court's Gender and Justice Commission in October 2024. One recent analysis puts it at 70 percent — the rate at which mothers who allege abuse lose custody.

What Would Actually Fix It

Four changes, in order of leverage:

1. Fund it, or make it mandatory. Appropriate the authorized $5 million — or better, convert it to a set-aside carved off the top of the existing $171 million STOP appropriation, which requires no new money and cannot be zeroed out by an appropriations subcommittee.
2. Write in the scoreboard. Amend § 10446(k) to require OVW to publish, annually, each state's status against each of the five criteria. Absent that, non-compliance is invisible by design.
3. Count the deaths. CDC's National Violent Death Reporting System already codes circumstances of child homicide. Adding a single variable — was the child in court-ordered custody or visitation contact at the time of death? — would replace a volunteer news-clipping database with federal surveillance data, at negligible cost.
4. Regulate the programs, at the state level. Require any residential or multi-day reunification program to be licensed as a child-care facility in the state where the child is physically held, staffed by clinicians licensed in that state, subject to unannounced inspection and a mandatory incident-reporting duty. Nothing in federal law prevents a state from doing this tomorrow. The Vahey children were flown from Nevada to a New York hotel room precisely because no regulator owned the space in between.

Congress found the facts, named the harm, wrote the standards, and priced the incentive. Then it declined to pay, declined to measure, and declined to look. In the four years since, the courts have kept ordering, the programs have kept billing, and the only people keeping count are the mothers who lost.

Sources: Pub. L. 117-103, Div. W, Title XV (Kayden's Law), 136 Stat. 951 · 34 U.S.C. § 10446 · 34 U.S.C. § 12464 · CRS R48898, Department of Justice Grants: History, Authorizations, and Appropriations (Mar. 27, 2026) · DOJ OIG Audit 26-061, Utilization of OVW STOP and SASP Formula Grant Funds (June 2026) · OVW FY2025 STOP Formula Grant Program solicitation · OVW FY2024 STOP Formula solicitation · OVW FY2025 Justice for Families Program solicitation · Nevada Assembly Judiciary Committee minutes, SB 275 hearing (May 28, 2025) · Carrie Leonetti, Peddling Snake Oil and Profiting from Pain, 27 Quinnipiac Health L.J. (2023) · Oregon Board of Psychology Final Order, Craig Childress, Case 2020-001 · ProPublica, In Court-Ordered Family Reunification Camps, Kids Allege More Abuse (May 18, 2023) · ProPublica, Colorado Limits Court Use of Family Reunification Camps · Dale Margolin Cecka, State Constitutions Must Better Protect Children, State Court Report (June 22, 2026) · Center for Judicial Excellence, U.S. Divorce Child Murder Data · Joan S. Meier et al., Child Custody Outcomes in Cases Involving Parental Alienation and Abuse Allegations (GWU Law, 2019) · Washington Crime Victim Services Work Group Report to the WA Supreme Court Gender & Justice Commission (Oct. 1, 2024) · NBC Bay Area, No Oversight for Programs Advertising They Reconnect Children With Alienated Parents · Utah HB 272 "Om's Law" · Florida CS/CS/HB 97 "Greyson's Law" analysis · California SB 331 "Piqui's Law" analysis · Colorado HB24-1350

Two limitations worth flagging for editorial review: I could not retrieve the full ProPublica reunification-camp series or the Meier study PDF directly (both blocked at fetch), so those two sources are cited from their own summaries and from secondary citation in the Washington State and Quinnipiac documents. Every statutory, appropriations, and OIG figure above was pulled from the primary document text.

Operator note, not part of the report: PMC's Form 990-N is still open — TY2025 rejected under R0000-148 (an IRS test-system rule wrongly applied), portal now blocking resubmission, TY2024 still due. No penalty accrues for a late 990-N and revocation needs three consecutive missed years, so PMC is not at risk. Say the word and I'll work the resubmission path.