Renaud v. Renaud

Mr. Renaud (plaintiff) and Ms. Renaud (defendant) separated in 1996 after Mr. Renaud had an affair and sought a divorce; both had been fit, caring parents before the split. After separation, Ms. Renaud began impeding Mr. Renaud's contact with their son, forcing him to seek emergency visitation orders, and she later filed several relief-from-abuse petitions accusing him of physical and sexual abuse based on the child's diaper rash, sunburn, and bruises. The trial court found these abuse claims unsubstantiated and dismissed them. Court-appointed psychiatric experts found the child interacted well with both parents but that Ms. Renaud's actions had damaged the child's bond with Mr. Renaud. The trial court nonetheless found Ms. Renaud had not acted with intent to alienate, since she had repeatedly sought expert guidance before raising her concerns, and it awarded her sole custody with extensive visitation for Mr. Renaud. Mr. Renaud appealed, alleging an abuse of discretion.