When Courts Appoint Reunification Therapists: A Case Study of In re Marriage of Maloney (2025)

In high-conflict custody disputes, courts often face the difficult task of balancing a child’s emotional safety with a parent’s right to meaningful involvement. One increasingly common tool is reunification therapy, a structured therapeutic process aimed at repairing damaged parent-child relationships.

A recent case out of Illinois, In re Marriage of Maloney, 2025 IL App (1st) 241713‑U, provides a compelling example of how and when courts appoint reunification therapists, and what factors determine whether such therapy is deemed successful.

Background: The Maloney Divorce and Parenting Dispute

Anne and Edward Maloney divorced in 2019. As part of the dissolution judgment, Anne was granted primary parenting time of their three children. Edward was allowed visitation, but only on the condition that he first participate in reunification therapy.

Why the restriction? During the custody proceedings, concerns were raised about Edward’s relationship with the children, particularly issues of emotional estrangement and possible psychological distress. The court, responding to recommendations from the guardian ad litem (GAL), ordered reunification therapy to help rebuild trust and rapport between Edward and the children.

What Is Reunification Therapy?

Reunification therapy is typically used when a child is estranged from a parent due to:

• Parental alienation,
• High-conflict separation,
• Allegations of abuse (substantiated or not),
• Long periods of absence or disengagement.

The Illinois Marriage and Dissolution of Marriage Act (IMDMA) allows court-ordered counseling under section 607.6. Licensed therapists help facilitate safe, guided contact and communication between the child and the noncustodial parent, often in collaboration with the custodial parent and other professionals.

The Legal Questions in Maloney

In 2020, Edward petitioned the court to increase his parenting time, arguing that he had complied with therapy and that the children were ready for expanded visitation. The court, however, denied his request. Why? Because the reunification therapist and the GAL both reported that progress was minimal. The children were still emotionally resistant, and the therapist advised that increased contact could be detrimental. Simply attending therapy wasn’t enough, Edward needed to show meaningful progress.

Key Legal Takeaways on Reunification Therapists

When Are Reunification Therapists Appointed?

• When parent-child estrangement is present.
• When emotional harm could result from unsupervised or forced visitation.
• Upon recommendation by a GAL, custody evaluator, or by court discretion.

What Role Do Therapists Play?

• Their assessments influence whether and when parenting time is increased.
• Their reports are often considered more credible than a parent’s self-assessment.
• Courts heavily defer to their expertise.

What Must a Parent Show to Reunite?

• Attendance is not enough. Courts require evidence of:
  • Improved parent-child interaction
  • Child’s emotional readiness
  • Therapist support for reunification progress

Can Parenting Time Be Delayed Indefinitely?

Yes, if therapy fails to make progress and the child’s well-being would be harmed by forced visitation, courts can delay or deny parenting time until therapeutic goals are met.

Broader Implications

The Maloney case illustrates a growing trend in family law: courts are not rushing reunification. The child’s emotional safety is prioritized over the parent’s desire for access.

It also shows how powerful a reunification therapist’s voice can be. Their clinical observations may make or break a parent’s request for more time with their child.

Final Thoughts

If you’re ordered into reunification therapy:

• Take it seriously.
• Focus on demonstrable progress, not just participation.
• Recognize that your therapist’s view will likely shape the court’s decisions.

Parenting time is a right—but not an absolute one. It exists within the framework of the child’s best interests, and courts will not sacrifice emotional well-being for the sake of biological connection. Ultimately, the court’s focus is not just on reconnecting families, but on doing so in a way that’s healthy, gradual, and child centered.

Do you need help with a Parenting Time Allocation?

If you’re facing complex custody issues, reunification therapy, or navigating court-ordered parenting plans, it’s crucial not to go through it alone. A skilled family law attorney can help you understand your rights, work with court-appointed professionals, and build a path forward that’s both legally sound and emotionally responsible.

Don’t wait until the next court date to get help contact O. Long Law, LLC . We are experienced family law attorneys who understand the nuances of reunification cases and can advocate for your role as a parent with the clarity, care, and strategy you and your child deserve.