GREEN v. GREER (2026)

This is a contentious child custody case. The mother, Jamie Sue Greer (hereinafter “Greer”), appeals the trial court's October 28, 2025 judgment, granting the father, Ronald Green (hereinafter “Green”), sole custody and granting Greer supervised visitation. Considering the record and the applicable law, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

The parties—Green and Greer—were married in 2019 and physically separated in 2021. The parties divorced in 2023, and of the marriage, one child, a girl was born—E.G.¹ E.G. was born in 2020.

During the marriage, the parties lived together in Belle Chase, Louisiana. When they separated, Greer maintained physical custody of E.G. in Belle Chase. In March 2022, Greer moved with E.G. to Waco, Texas. This move—although initially opposed by Green—was authorized by a December 2021 consent judgment. The purpose of the move to Waco was for Greer to complete a PhD in education at Baylor University. Greer graduated in May 2025. The following month, Greer moved with E.G. to Lafayette, Indiana, where Greer's mother lived. This move was done without informing the trial court, the court-appointed custody evaluator, or Green.²

The precipitating event that triggered the parties’ divorce was Greer's signing an affidavit, on March 25, 2021, with the Plaquemines Parish coroner's office to have Green involuntarily committed for mental health issues. Green, a veteran, was diagnosed with PTSD before the parties were married and had received treatment through the Veterans Administration (hereinafter “VA”). Based on Greer's affidavit, Green was involuntarily committed.³ He was released on April 1, 2024. Within a week of his release, Green filed a petition for divorce.

Four months later, in August 2021, Green filed a Rule to Establish Custody with Request for Emergency Custody by Parent (hereinafter “the 2021 Rule”). In the 2021 Rule, Green sought ex parte temporary sole custody, permanent joint custody, and designation as domiciliary parent.⁴ In June 2024, Greer filed a motion to transfer the case to Texas, which the trial court denied.⁵ During the four-year period between the filing of the 2021 Rule and the 2025 custody trial, the trial court issued multiple interim judgments regarding custody. The trial court's first final custody judgment was the October 28, 2025 judgment issued following the custody trial, which is the subject of this appeal.

In December 2021, an interim judgment was rendered permitting Greer's relocation to Waco. When Greer and E.G. relocated to Waco, Green initially had supervised visitation. At that time, the custody supervisor was Patricia Percy (hereinafter “Percy”), a licensed clinical social worker. Thereafter, Green was allowed unsupervised visitation on alternating weekends in the Beaumont, Texas area.

In October 2022, the trial court entered a judgment awarding joint custody on an interim basis and without prejudice. In that judgment, the court ordered the parties to promptly participate in a custody evaluation with Dr. Karen Van Beyer. Due to scheduling issues, Dr. Van Beyer withdrew. She was replaced, in February 2023, by Terri Campesta, LPC, LMFT (hereinafter “Campesta”).⁶ In her capacity as court-appointed custody evaluator, Campesta authored two custody reports in this case—an initial report on May 20, 2024; and a supplemental report on July 11, 2025. In the initial report, Campesta recommended joint custody with Greer as the domiciliary parent; in the supplemental report, she recommended “immediate” sole custody be awarded to Green.

Eight days before Ms. Campesta's initial report was issued, on May 12, 2024, E.G., according to Greer, reported that Green had sexually abused her. E.G. told this to Greer while they were driving home to Waco from a May 12, 2024 custodial visit with Green in Beaumont. About half-way home, they stopped at a bathroom in the College Station area. While in the bathroom, Greer claims that E.G. told her that “my dada ouched me there.” When they went back to the vehicle, Greer had E.G. repeat what happened so that she could record E.G.’s statement. Greer then drove home. When they arrived home, Greer bathed E.G. and put her to sleep. The next day Greer brought E.G. to the Waco Police Department to report the incident. The Waco Police Department recommended Greer take E.G. to the hospital, which Greer did. At the hospital, a SANE exam was done.⁷ Afterwards, E.G. was subjected to a forensic interview. Because of the location of the alleged abuse, the Waco Police Department transferred the matter to the Beaumont Police Department.

Citing the alleged sexual-abuse incident, Greer, on May 24, 2024, filed an emergency motion for ex parte sole custody. The trial court granted the motion and ordered that Green have no physical contact with E.G. Electronic communication—face time calls—was permitted on a limited basis. Thereafter, Green had no in-person contact with E.G. for over a year. Given the change in circumstances, the trial court ordered Campesta to update her custody evaluation.

Meanwhile, in February 2025, the Beaumont Police Department reported the disposition of the criminal investigation as “prosecution declined.” But, two weeks later, the Louisiana Department of Children and Family Service (hereinafter “DCFS”) received a report of Green's alleged abuse. Ultimately, the DCFS found insufficient information to support abuse or neglect. In May 2025, DCFS classified the report as “invalid (not justified).”⁸

In July 2025, Campesta issued a supplemental report recommending that Green be awarded “immediate” sole custody. In her supplemental report, Campesta stated that Greer was seeking “full custody” and that Green was seeking “sole, full custody,” with any custodial time awarded to Greer initially supervised.

Citing Campesta's supplemental recommendation, Green, in July 2025, filed a Motion for Order of Interim Sole Custody. Thereafter, the parties entered an interim consent judgment and deferred all remaining custody motions to the custody trial. One of those remaining motions was Green's sole-custody request.

A three-day custody trial was held from September 30 to October 2, 2025. At trial, both Green and Greer testified. In addition, four non-party witnesses testified: Kelly Pickett (hereinafter “Pickett”); Martha Bujanda, LPC (hereinafter “Bujanda”); Campesta; and Alicia Pellegrin, PhD (hereinafter “Dr. Pellegrin”). Given the fact-intense nature of the issues presented, we briefly summarize the non-party witnesses’ testimony.

 Pickett

Pickett testified that she has known Green for over thirty years and that they are close family friends. Both are from the Coushatta, Louisiana area. Pickett further testified that she is both a teacher and an LPC. One of her work colleagues, Ross Gamble (hereinafter “Gamble”), is Green's counselor. Pickett referred Green to Gamble.

Pickett and her husband traveled with Green to Indiana for several of his custodial visits with E.G. They also accompanied Green on his custodial visits that took place in the New Orleans area shortly before the custody trial. On some of those custody visits, Pickett also brought her granddaughter, who is roughly E.G.’s age. According to Pickett, E.G. was not hesitant to transition to her father for the visits. Pickett described E.G. as excited to see her father. Pickett testified that although E.G. enjoyed her visits with them, E.G. asked Pickett not to tell her mother that they were having fun. A picture of Pickett, her husband, her granddaughter, E.G., and Green that was taken during one of the custodial visits was introduced at trial.

 Bujanda

Bujanda, an LPC, was retained as a visitation supervisor in this case. According to Bujanda, Greer informed her at the initial intake session that in June 2025 Greer was moving with E.G. to Indiana.

On July 12, 2025, Bujanda supervised Green's first in-person visit with E.G. following the lengthy separation that resulted from the sexual abuse allegation. The three-hour visit took place at Bujanda's Harahan, Louisiana office. Green showed up for the visit with numerous boxes of toys and food, which Bujanda described as “impressive.” Bujanda characterized E.G. as “stiff” when she arrived for the visit. When Green was showing E.G. a photo album, E.G. referred to the memories as “fake happy time.” Although E.G. replied to her father that she loved him, she stopped and said, “My mom says I shouldn't.” Bujanda explained that it is rare for a child to make that statement. Bujanda testified that during the visit she observed many red flags—times when E.G. held back because she felt like she was betraying her mother.

 Campesta

Campesta is the court appointed custody evaluator. The parties stipulated to Campesta's qualification as a custody-evaluation expert. As noted elsewhere in this opinion, Campesta authored two custody reports in this case—an initial report on May 20, 2024; and a supplemental report on July 11, 2025. Both reports were introduced into evidence.

Campesta testified that the main change between her two reports was the sexual abuse allegation. She explained that custody evaluators do not perform investigations. Rather, custody evaluators rely on investigative professionals—the police and DCFS—to investigate. Based upon the investigative professionals’ reports that she reviewed, Campesta did not believe the sexual-abuse allegation. Campesta commented that she believed it was “abuse” for a mother to subject a child to a SANE exam and a forensic interview if the mother did not believe the abuse allegation to be true. Based on the reports and collateral witnesses that she interviewed, Campesta believed the risk of abuse of E.G. by Green was minimal.

Campesta characterized the sexual-abuse allegation by Greer as the “cherry on top” in terms of Greer's escalating allegations against Green. Campesta explained that Greer's allegations dated back to before the parties were married in 2019. Campesta characterized an event that occurred shortly before the parties separated, on March 21, 2021, as demonstrating Greer's “adult emotional reactivity”—exaggerated emotional response to a situation.

The March 21, 2021 event occurred when the parties, with E.G. in the vehicle, were driving from Houston to their home in Belle Chase. Green was driving and had on ear pods. He was listening to podcasts. Greer pulled out Green's ear pods, startling him. Greer claimed that Green slammed on the brakes, causing Greer and their family dog to fly forward, and the dog to hit the windshield. This incident culminated in Greer calling 911.

An Acadia Parish police officer (hereinafter “the Officer”) responded and investigated Greer's March 21, 2021 complaint. The Officer questioned Green. The Officer saw nothing in Green's behavior based on which he could take action. The Officer, thus, determined that Greer's complaint was unwarranted. When the Officer related his finding to Greer, her demeanor changed from sad and quiet to calm and frustrated. In response to Greer's question as to how she could get help, the Officer told her that she could go to the parish coroner and obtain a protective order. Despite her concerns about Green's erratic driving, Greer then told the Officer that she felt safe with Green driving her and E.G. home. In his report, the Officer wrote that Greer's response that she felt safe in the vehicle concerned him. The Officer also wrote in his report that he had seen “these instances take place where a report is eventually filed in different jurisdictions so that the outcome that is wanted takes place.” The Officer advised Green to record the remainder of the ride home for his protection.⁹

Similarly, Campesta voiced “credibility” concerns regarding several of Greer's other allegations. Campesta pointed out that on her last visit with Greer during the first evaluation, Greer, for the first time, alleged that she found child pornographic images on Green's iPad. Greer also alleged that she saw on social media that Green was an alcoholic.

Campesta found it telling that other professionals, including the trial judge, had expressed doubt as to Greer's credibility. Campesta noted that Greer, in June 2024, filed a motion to move the case to Texas, which the trial court denied. Campesta believed that such a transfer was inappropriate given the trial court's awareness of the nuances of this case. Campesta also noted the trial court's statement, in connection with its February 2023 judgment on a divorce issue, that he found Greer's testimony lacked credibility and reliability. Similarly, Campesta cited a statement by Ms. Percy, one of the custody supervisors, that she found Greer “manipulative.”

Addressing Greer's parental abilities, Campesta testified that Greer's only weakness as a parent is her failure to wholeheartedly encourage contact and a relationship with Green. But Campesta qualified this statement as pre-dating the sexual-abuse allegation. Campesta described Greer's interactions with E.G. as warm, caring, affectionate, spontaneous, and very natural. Campesta acknowledged that Greer was capable of providing for E.G. and that she had done so. Campesta voiced disagreement with Greer's statement that she was using parallel parenting—each parent doing their own thing. Campesta observed that parallel parenting is not co-parenting, which is what joint custody requires.

Focusing on E.G., Campesta described her as bright and very articulate. Campesta expressed concern over Greer's calling E.G. by the nick name “L.J.”—Little Jamie. Campesta noted that doing so was inappropriate given E.G.’s developmental age.

Campesta testified that the recordings that she reviewed, several of which were introduced and played at trial, had a theme—dad is bad and violent. The recordings also had a negative tone. Instead of saying dad is sending sunshine so mom's flowers will grow, E.G. says in the recordings that dad is sending a blizzard to kill mom's roses. Campesta pointed out the adult-oriented content to which E.G. was being exposed was reflected in some of the recordings. Illustrative of this were recordings of E.G. allegedly stating that her mother told her that her father was going to kill her mommy and kill her.

As to Green's PTSD diagnosis, Campesta testified that Green was treating with a counselor, Gamble, and that she believed this was sufficient. She also observed that although psychosis was noted on the intake of Green's involuntary commitment, it was not in the discharge diagnosis. Finally, Campesta testified that Green has a support unit to help him be a single parent in both the New Orleans and Plaquemines areas as well as in Northern Louisiana where his family lives.

As noted elsewhere in this opinion, Campesta's supplemental report concluded with the recommendation that “immediate” sole custody be awarded to Green to avoid any further detriment to E.G. She observed that negative messages and allegations by Greer were detrimental to E.G. and needed to be stopped as soon as possible to avoid harm to E.G.

 Dr. Pellegrin

Dr. Pellegrin was qualified as an expert in the fields of clinical and forensic psychology, child sexual abuse, and custody evaluation. Her report was admitted into evidence. Dr. Pellegrin limited her testimony by alerting the court that she only had contact with one parent—Green—who retained her as an expert. Nonetheless, Dr. Pellegrin testified that she heard the recordings that were played in court of the other parent—Greer. According to Dr. Pellegrin, Greer's recordings were consistent with parental alienating behavior and borrowed scenarios.¹⁰

Dr. Pellegrin described parental alienation as a series of behaviors seen in children who have been turned against one parent or the other. She acknowledged that parental alienation is not a recognized syndrome, but she described it as a legitimate dynamic in many family situations. She testified that it typically involves manipulative or escalating alienating behaviors, such as sexual abuse allegations. Dr. Pellegrin opined that this case presents with hallmark signs of parental alienation.

According to Dr. Pellegrin, Green's PTSD is a red herring in this custody dispute. She explained that every parent evaluated has something. She characterized Green's therapy with Gamble as addressing everyday stressors and noted that Green also receives support from the VA's therapists for his PTSD.

Dr. Pellegrin, like Campesta, expressed concerns over Greer's use of the nickname L.J. for E.G. Dr. Pellegrin explained that names are important for identity and development.

On October 28, 2025, the trial court rendered judgment awarding sole custody to Green, supervised visitation to Greer, and regular electronic contact with Greer. The judgment ordered, among other things, that custody of E.G. be turned over to Green at the Indianapolis International Airport on December 20, 2025. The trial court also provided the following detailed reasons for judgment:¹¹

[T]his Court places significant weight on the testimony of the court-appointed custody evaluator, Terri Campesta. Of paramount importance and concern, Ms. Campesta testified that the behaviors exhibited by the child's mother, Jamie Greer, can be considered ongoing mental and psychological abuse in the form of interference by Jamie Greer with the relationship between the parties’ daughter and her father.

Further Ms. Campesta testified with a great deal of concern that Ms. Greer commented that she was attempting to use “parallel” parenting, which was essentially found to be a “parenting” method whereby neither parent shares any information with the other. Ms. Campesta explained that “parallel” parenting is not appropriate for this situation and is detrimental to the child.

Ms. Campesta's evaluation also detailed over twenty (20) separate allegations made by Ms. Greer against Mr. Green, including claims of abuse of both Ms. Greer and the child as well as other misconduct. None of these allegations were supported by independent facts, evidence, nor supported by law enforcement or other social services organizations that investigated, nor by any collateral witnesses. The evaluator found that Ms. Greer failed to provide credible evidence to corroborate her claims and specifically found that the allegations were of a deliberate and continuing nature and were escalating.

Ms. Campesta's first evaluation included a recommendation that the parties should live no further apart. However, during the updated evaluation Ms. Greer, with no notice to anyone, moved her and her daughter to Lafayette, Indiana. Mr. Green testified that he did not consent to this move, and there is no request to move in the record of this matter. Ms. Campesta testified that she was not aware of the move until after the updated evaluation was concluded. Ms. Campesta testified that, in her opinion, amongst other tactics (as described above), Ms. Greer was intentionally exploiting the distance between the parties to prevent her daughter from spending time with the father.

Ms. Campesta also reviewed several documents and recordings that were submitted as evidence. These included several recordings of the minor child allegedly stating that she was told by her mother that Mr. Green was going to kill her mommy, kill her, and had sent a blizzard to kill their roses, etc. Ms. Campesta testified that these recordings were evidence of the adult-oriented content that the daughter was being exposed to by Ms. Greer.

Mr. Green called expert witness, Dr. Alicia Pellegrin, who corroborated Ms. Campesta’ position. Dr. Pellegrin testified that Ms. Greer's conduct amounted to parental alienation and constituted abuse. Both experts agreed that the abuse was ongoing and would likely escalate without the Court's intervention.

Ms. Greer did not call any expert witnesses to opine on or refute Ms. Campesta's report or any other opinion that may have supported her case or refuted any of Mr. Green's positions.

It is found that Jamie Greer's testimony lacked credibility and was not compelling. Notably, she stated that she had no responsibility for Mr. Green's commitment, despite having signed the affidavit for his commitment. Her case in chief focused primarily on reasserting her false allegations of abuse by Mr. Green, rather than refuting the findings of the two experts.

Accordingly, for the reasons stated above, on the whole, the Court concludes that the evaluator's findings were thorough, well-supported, and consistent with the best interest of the child. Therefore, the Court adopts Ms. Campesta's recommendation of sole legal custody to Ron Green and further adopts her recommendations, with some variations.

This appeal followed.¹²

STANDARD OF REVIEW

“Ordinarily, child custody cases are reviewed under the abuse of discretion standard.” Cook v. Sullivan, 2020-01471, p. 6 (La. 9/30/21), 330 So.3d 152, 157 (citation omitted). But “where one or more trial court legal errors interdict the fact-finding process, the manifest error/abuse of discretion standard is no longer applicable, and, if the record is otherwise complete, the appellate court should make its own independent de novo review of the record and determine the sufficiency of the evidence.” Id. (citation omitted) “A legal error occurs when a trial court applies incorrect principles of law and such errors are prejudicial.” Id. at pp. 6-7, 330 So.3d at 157 (citation omitted). “Absent a legal error, a trial court's child-custody determination is reviewed under an abuse of discretion standard.” Council v. Livingston, 2019-1049, p. 11 (La.App. 4 Cir. 3/13/20), 364 So.3d 410, 418 (citation omitted); England v. England, 2018-0056, p. 5 (La.App. 4 Cir. 7/5/18), 251 So.3d 699, 703 (quoting Hilkirk v. Johnson, 2015-0577, p. 25 (La.App. 4 Cir. 12/23/15), 183 So.3d 731, 746) (observing that “ ‘[c]hild custody determinations made by the trial court are entitled to great weight and, upon appellate review, that determination will not be disturbed absent a clear showing of abuse of discretion.’ ”).

As this Court has observed, “[i]n most child custody cases and, by analogy, in visitation cases, the trial court decisions are based heavily on factual findings.” Garner v. Thomas, 2008-1448, p. 9 (La.App. 4 Cir. 5/28/09), 13 So.3d 784, 789 (citing Palazzolo v. Mire, 2008-0075 (La.App. 4 Cir. 1/7/09), 10 So.3d 748). This Court likewise has observed that “the trial court is vested with much discretion in visitation matters under LSA-C.C. art. 132 and his findings will not be disturbed absent an abuse of discretion.” Zatzkis v. Zatzkis, 632 So.2d 307, 320 (La.App. 4th Cir. 1993) (citation omitted).

DISCUSSION

On appeal, Greer assigns three errors:

1. The trial court committed legal error by awarding sole custody to Green under La. C.C. art. 132 where he neither requested that relief in his Rule to Establish Custody nor met his burden of proving by clear and convincing evidence that it was in E.G.’s best interest.

2. The trial court committed legal error by misapplying La. C.C. art. 134 and finding that parental alienation constituted abuse under Louisiana law and jurisprudence.

3. The trial court committed legal error by restricting Greer to supervised visitation with E.G.

Greer couches all three of her assignments as legal errors. In so doing, Greer attempts to elevate the applicable standard of review from the deferential abuse of discretion standard to the more demanding de novo standard. As discussed elsewhere in this opinion, we find no prejudicial error of law requiring us to determine the facts de novo. As such, we apply an abuse of discretion standard to all the issues raised.

The custody and visitation issues raised are governed by four Louisiana Civil Code articles—La. C.C. articles 131, 132, 134, and 136.

Article 131 provides that “the court shall award custody of a child in accordance with the best interest of the child.” La. C.C. art. 131.

Article 132 provides, in pertinent part, that “if custody in one parent is shown by clear and convincing evidence to serve the best interest of the child, the court shall award custody to that parent.” La. C.C. art. 132. Under Article 132, a parent seeking sole custody bears the burden of proving that “the granting of custody to that parent alone will be in the best interest of the child.” Griffith v. Latiolais, 2010-0754, p. 13 (La. 10/19/10), 48 So.3d 1058, 1068 (citation omitted). Moreover, “clear and convincing evidence is applied in civil cases only in exceptional circumstances, where there is thought to be special danger of deception, or where the court considers that particular type of claim should be disfavored on policy grounds.” Id. at p. 17, 48 So.3d at 1070 (citations and internal quotations omitted). “The clear and convincing standard requires a party to prove the existence of a contested fact is highly probable, or much more probable than its non-existence.” Id. at p. 18, 48 So.3d at 1070 (citations and internal quotations omitted).

Article 134 requires a court to consider all relevant factors in making the best-interest-of-the-child determination and enumerates the following fourteen, non-exclusive factors that courts are to consider:

(1) The potential for the child to be abused, as defined by Children's Code Article 603, which shall be the primary consideration.

(2) The love, affection, and other emotional ties between each party and the child.

(3) The capacity and disposition of each party to give the child love, affection, and spiritual guidance and to continue the education and rearing of the child.

(4) The capacity and disposition of each party to provide the child with food, clothing, medical care, and other material needs.

(5) The length of time the child has lived in a stable, adequate environment, and the desirability of maintaining continuity of that environment.

(6) The permanence, as a family unit, of the existing or proposed custodial home or homes.

(7) The moral fitness of each party, insofar as it affects the welfare of the child.

(8) The history of substance abuse, violence, or criminal activity of any party.

(9) The mental and physical health of each party. Evidence that an abused parent suffers from the effects of past abuse by the other parent shall not be grounds for denying that parent custody.

(10) The home, school, and community history of the child.

(11) The reasonable preference of the child, if the court deems the child to be of sufficient age to express a preference.

(12) The willingness and ability of each party to facilitate and encourage a close and continuing relationship between the child and the other party, except when objectively substantial evidence of specific abusive, reckless, or illegal conduct has caused one party to have reasonable concerns for the child's safety or well-being while in the care of the other party.

(13) The distance between the respective residences of the parties.

(14) The responsibility for the care and rearing of the child previously exercised by each party.

La. C.C. art. 134(A).

Lastly, Article 136 provides that “a parent not granted custody or joint custody of a child is entitled to reasonable visitation rights unless the court finds, after a hearing, that visitation would not be in the best interest of the child.” La. C.C. art. 136(A).

In analyzing the issues raised on appeal, we divide our discussion into three sections—sole custody, parental alienation, and supervised visitation.

Sole custody

Greer first argues that the trial court legally erred in awarding sole custody to Green. This argument has two parts: (i) sole custody was not properly before the trial court because Green's 2021 Rule requested sole custody and was never amended; and (ii) the evidence did not clearly and convincingly establish that sole custody was in E.G.’s best interest. Greer cites the Griffith case as supporting both parts of her argument.

Greer's reliance on Griffith is misplaced. The Griffith case, as Green points out, presented in a materially different procedural posture. There, the mother requested joint custody and a domiciliary parent designation in the trial court; and the trial court awarded joint custody. Griffith, 2010-0754, p. 8, 48 So.3d at 1065. On appeal, the court of appeal reversed and awarded the mother sole custody—relief she never requested and relief that was never litigated in the trial court. Id. at p. 11, 48 So.3d at 1066. Reversing and reinstating the trial court's decision, the Supreme Court cited not only the procedural problem that the mother never requested sole custody, but also the evidentiary problem that the record was devoid of clear and convincing evidence that sole custody was in the child's best interest. Id. at pp. 18-19, 48 So.3d at 1070-71. All the experts testified that custody should be shared; no expert testified that sole custody was in the child's best interest. Id. Neither the procedural nor the evidentiary problem presented in Griffith is presented here.

Procedurally, the issue of sole custody was properly before the trial court. Green requested sole custody before trial, filing a motion in July 2025; the court-appointed evaluator recommended it; and sole custody was among the issues litigated during the three-day custody trial. Greer, thus, had notice that Green was seeking sole custody; and she had an opportunity to contest it.

As to the evidence, unlike in Griffith, an abundance of evidence was presented at the custody trial supporting the sole custody award. The child-custody evaluator, Campesta, citing Greer's escalating allegations against Green, recommended sole custody. Green's expert, Dr. Pellegrin, corroborated Campesta's concerns about Greer's escalating allegations being harmful to E.G.’s relationship with her father. Both experts feared that E.G.’s relationship with her father would deteriorate if the mother's conduct continued. Thus, the trial court's award of sole custody to Green was made after it took evidence, including expert testimony, supporting the sole custody award. Accordingly, Greer's first argument that the sole custody award was legally erroneous is unpersuasive.

Parental Alienation

A trio of cases have recognized that parental alienation is factored into the best-interest-of-the-child determination set forth in La. C.C. art. 134 under two factors—Factors (7) and (12). See England, 2018-0056, p. 7, 251 So.3d at 704; Hilkirk, 2015-0577, pp. 37-38, 183 So.3d at 752; Palazzolo, 2008-0075, p. 46-47, 10 So.3d at 775.¹³ Factor (7) is “[t]he moral fitness of each party, insofar as it affects the welfare of the child.” La. C.C. art. 134(A)(7). Factor (12) is “[t]he willingness and ability of each party to facilitate and encourage a close and continuing relationship between the child and the other party ․” La. C.C. art. 134(A)(12).¹⁴

“Abuse” is addressed separately in Factor (1), which provides: “[t]he potential for the child to be abused, as defined by Children's Code Article 603, which shall be the primary consideration.” La. C.C. art. 134(A)(1). Article 134(A)(1) has two parts: (i) it expressly incorporates the definition of “abuse” contained in La. Ch. C. art. 603, thereby limiting the scope of “abuse” covered by Factor (1);¹⁵ and (ii) it elevates the potential for such abuse to the primary consideration in determining a child's best interest.

Greer's second argument is that the trial court legally erred in treating parental alienation as “abuse” under Factor (1), elevating it as the primary consideration in determining E.G.’s best interest. In support, Greer cites the trial court's reasons for judgment. In its reasons for judgment, the trial court incorporated the two experts’ opinions that Dr. Greer's interference with E.G.’s relationship with her father—parental alienation conduct—constituted “ongoing mental and psychological abuse.” Greer contends that such parental alienation conduct does not satisfy the statutory definition of “abuse” under La. Ch. C. art. 603(2).

Continuing, Greer also contends that parental alienation should have been considered under only Factors (7) and (12), not Factor (1). In support, Greer cites the trio of cases in which this Court has applied that analysis—England, Hilkirk, and Palazzolo. The trial court's erroneous classification, Greer contends, elevated parental alienation to the primary consideration in determining E.G.’s best interest, which was a misapplication of the law.

Green counters that that Greer is attempting to convert a terminology dispute into reversible legal error. Even assuming the trial court erred in characterizing the parental alienation conduct as “abuse,” Green contends that the error neither removed relevant evidence from the trial court's consideration, nor caused the court to consider evidence it otherwise could not consider. Regardless of whether the conduct is labeled “abuse,” alienating conduct, or interference with the parent-child relationship, the underlying facts remain the same. Those underlying facts were independently relevant and properly before the trial court. According to Green, Greer posits a false choice—either Greer's conduct constitutes “abuse” under La. C.C. art. 134(A)(1) or the custody determination falls.

Contrary to Greer's contention, we find any error in the trial court's use of the term “abuse” in its reasons for judgment did not interdict the trial court's factfinding process and, thus, does not provide a basis for a de novo review. We find, as Green contends, that the trial court's judgment did not turn on the label “abuse.” Rather, it turned on the trial court's consideration of all the relevant underlying facts, including Greer's parental alienation conduct. The record reflects, as Campesta testified, that Greer made escalating accusations against Green that were unsupported. Greer exposed E.G. to adult-themed accusations concerning her father. The record also reflects that E.G. had begun expressing fear of her father based on statements she attributed to her mother and had become conflicted over whether she was permitted to express affection toward her father. This evidence of alienating conduct adversely affecting E.G.’s relationship with her father was independently relevant to the best-interest determination and was properly considered under La. C.C. art. 134(A)(7) and (12). The trial court did not err in factoring Greer's parental alienation conduct into its best-interest-of-the-child analysis.

Although the Legislature has recognized that “abuse” under Factor (1) is the paramount consideration, not all child custody cases involve “abuse” as defined in La. Ch. C. art. 603(2). In determining the best interest of the child in cases not involving such “abuse,” La. C.C. art. 134 requires a court to consider all relevant factors, including the fourteen enumerated factors. Again, Factors (7) and (12) are the two factors relevant to parental alienation. As to the other twelve factors, the jurisprudence has recognized that a trial court is not required to mechanically recite each factor; rather, “[t]he illustrative nature of the listing of factors contained in Article 134 gives the court freedom to consider additional factors; and, in general, the court should consider the totality of the facts and circumstances of the individual case.” Hodges v. Hodges, 2015-0585, p. 4 (La. 11/23/15), 181 So.3d 700, 703 (citation omitted). As this Court has observed, custody determinations cannot be made “in a vacuum;” instead, “[a]ll events that potentially affect the child[ ] must be considered.” England, 2018-0056, p. 10, 251 So.3d at 705.

Applying those principles the case sub judice, the trial court, in its reasons for judgment, fails to mention any of the La. C.C. art. 134 factors. Nonetheless, the trial court's findings in its reasons for judgment, quoted elsewhere in this opinion, reflect that it considered multiple factors in making its determination that it was in E.G.’s best interest to award sole custody to Green. The trial court addressed the course of this litigation, which has been before the same trial court judge since 2021; the lengthy interruption of Green's contact with E.G.; Greer's unauthorized move to Indiana; Campesta's changed recommendation; Dr. Pellegrin's corroborating testimony; and questions regarding Greer's credibility. Indeed, the trial court found that in this case “Greer's testimony lacked credibility and was not compelling.” Taken together, the factors cited by the trial court establish that its best-interest-of-the-child determination was not an abuse of discretion.

Supervised Visitation

Greer's final argument is that the trial court legally erred by restricting her to supervised visitation. The governing statutory provision is La. C.C. art. 136(A), which provides that a parent not granted custody is entitled to reasonable visitation rights. Greer contends that supervised visitation was unwarranted given the lack of evidence that she posed a threat of physical harm to E.G. According to Greer, the trial court's reasons for judgment indicate that the restrictions on her visitation were based on the same conduct the court characterized as parental alienation and psychological abuse. Particularly, the trial court relied on the experts’ concern that the conduct would continue and eventually harm E.G.’s relationship with Green. Greer contends that the restrictions imposed cannot be reconciled with either the governing statute, La. C.C. art. 136(A), or the Hilkirk and England cases.

Green counters that the trial court has the authority to tailor visitation to minimize harm to the child and that such harm is not confined to physical injury. Green contends that the supervision requirement was imposed here to address the harm the trial court found—Greer's continued interference with E.G.’s relationship with her father and exposure to adult-themed accusations regarding him. Green emphasizes that Greer was awarded immediate in-person visitation and electronic access to E.G. Viewed as a whole, Green contends that the trial court's judgment preserved mother-daughter contact, while providing safeguards against the harmful conduct the court found was occurring. We find this argument persuasive.

Greer's counter argument that lesser restrictions were imposed in other cases despite alienating conduct is unpersuasive. “Every child custody case must be reviewed in light of the particular facts of that case and the relationships of the parties involved, with a goal of determining the best interest of the child.” Braud v. Braud, 2018-0874, p. 2 (La.App. 4. Cir. 12/12/18), 261 So.3d 950, 952 (citation omitted). Given the record of this case, we cannot conclude that the trial court's imposition of a supervised visitation requirement is an abuse of discretion.

DECREE

For the foregoing reasons, the trial court's October 28, 2025 judgment is affirmed.

AFFIRMED

FOOTNOTES

1.   In this opinion, we use the minor child's initials to protect her identity and privacy. See Uniform Rules, Courts of Appeal, Rules 5-1 and 5-2; see also Fulton v. Fulton, 2024-0810, p. 1, n.2 (La.App. 4 Cir. 4/17/25), 414 So.3d 955, 957.

2.   From 2022 to August 2024, Green continued to reside in Belle Chase. In August 2024, he moved to Coushatta, Louisiana, but he maintained a travel trailer in New Orleans where he stayed for work. Shortly before the custody trial, Green rented a house in Metairie, Louisiana.

3.   Greer subsequently signed another affidavit recanting her allegations that resulted in the issuance of the commitment order.

4.   This custody dispute has been pending before the same trial court judge since 2021.

5.   In February 2023, the trial court ruled on Greer's rule to find her free from fault in the divorce. In that divorce ruling, the trial court stated that it found “the testimony of the mover to be inconsistent and incongruent with other evidence received at the trial on the merits.” The trial court thus found Greer's testimony lacked credibility and reliability.

6.   “LPC” is the abbreviation for Licensed Professional Counselor; “LMFT” is the abbreviation for Licensed Marriage and Family Therapist.

7.   A SANE exam is a “forensic medical examination․provided to the victim of a sexually oriented criminal offense by a health care provider for the purpose of gathering and preserving evidence of a sexual assault for use in a court of law.” La. R.S. 15:622(A)(2).

8.   Because Green was employed as a federal law-enforcement agent, both the sexual-abuse allegation and the involuntary commitment prompted his employer to investigate. According to Green, at the time of the custody trial he again held his security clearance.

9.   As discussed elsewhere in this opinion, four days after the March 21, 2021 incident, Greer filed an affidavit with the Plaquemines Parish Coroner and had Green involuntarily committed. Thereafter, she filed an affidavit recanting her allegations that resulted in the involuntary commitment.

10.   “Borrowed scenario” means “[t]he child's presentation carries a rehearsed quality. They use language and expressions that are clearly not their own. Their verbalizations appear to be coached and rehearsed, and the only source of the borrowed scenarios appears to be the alienating parent.” Palazzolo v. Mire, 2008-0075, p. 41 (La.App. 4 Cir. 1/7/09), 10 So.3d 748, 772.

11.   Although appellate courts review judgments not reasons for judgment, we quote the trial court's reasons for judgment for two reasons. First, Greer's arguments are based, in part, on the trial court's reasons for judgment. Second, the jurisprudence has recognized that “a court of appeal can use reasons for judgment to gain insight into the district court's judgment.” Mathes Brierre Architects v. Karlton/ISG Enters., LLC, 2019-0357, p. 13 (La.App. 4 Cir. 12/3/20), 311 So.3d 532, 541, n.9 (citation and internal quotations omitted). We find it appropriate to do so here.

12.   After the trial court rendered its judgment, Greer filed a protective order against Green in Indiana. The result of her filing in Indiana was a delay in the transfer of E.G. to Green's custody. Although the judgment required the transfer of the child to occur on December 20, 2025, the transfer did not occur until April 28, 2026.

13.   In England, this Court observed that during the 2018 Regular Session the Legislature amended La. C.C. art. 134 but indicated that the amendment did not have an effect on its analysis. 2018-0056, p. 7, 251 So.3d at 704, n.6. Under the pre-2018 amendment version of La. C.C. art. 134, there were twelve enumerated factors; and the two factors that related to parental alienation were Factors (6) and (10). See England, 2018-0056, p. 7, 251 So.3d at 704 (observing that “[t]his Court has previously determined that two of the twelve factors relate to parental alienation, factors six and ten.”). Currently, La. C.C. art. 134 has fourteen factors; the content of the two factors that relate to parental alienation now appears in Factors (7) and (12).

14.   Factor (12) contains an exception for “when objectively substantial evidence of specific abusive, reckless, or illegal conduct has caused one party to have reasonable concerns for the child's safety or well-being while in the care of the other party.” La. C.C. art. 134(A)(12).

15.   La. Ch. C. art. 603(2) defines “Abuse” to mean as follows:“Abuse” means any one of the following acts that seriously endanger the physical, mental, or emotional health, welfare, and safety of the child:(a) The infliction, attempted infliction, or, as a result of inadequate supervision, the allowance of the infliction or attempted infliction of physical or mental injury upon the child by a parent or any other person.(b) The exploitation or overwork of a child by a parent or any other person, including but not limited to commercial sexual exploitation of the child.(c) The involvement of the child in any sexual act with a parent or any other person, or the aiding or toleration by the parent, caretaker, or any other person of the child's involvement in any of the following:(i) Any sexual act with any other person.(ii) Pornographic displays.(iii) Any sexual activity constituting a crime under the laws of this state.(d) A coerced abortion conducted upon a child.(e) Female genital mutilation as defined by R.S. 14:43.4 of the child or of a sister of the child.

Judge Tiffany Gautier Chase