Who said the Court of Appeals doesn’t believe in parental alienation syndrome? Some very interesting social theories are adopted as law by the Court of Appeals in an unpublished parental rights termination case, Ange v. Chesapeake Department of Human Services, 12 VLW 1106 (2/3/98). This was a challenge to termination that turned upon the Code §16.1-238(A) requirement of duly considering placement with the father’s relatives before terminating his rights. The Court of Appeals holds that the DSS properly investigated these relatives and the court properly found that neither of them, the grandmother nor the aunt of the child, offered the required “beneficial alternatives.” First, although foster care would seem to be a temporary expedient from which children are supposed to be removed, and removed promptly, in this case a psychologist and a social worker opined that to remove this child from her foster home is such a horrible idea that it would cause “regression” and “mental decompensation” inducing “psychosis.” And while one social worker found the father’s sister’s home to be an appropriate placement, this social worker was shown not to have known the extent of the domestic abuse that this aunt had suffered at the hands of her estranged husband. Another very interesting ground, stated for finding another of the father’s sisters unworthy, is that she is a mother who had abducted her own children from their father’s care, and hid them for several weeks by moving them from hotel to hotel.