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Tsimhoni v Eibschitz-Tsimhoni / Eibschitz-Tsimhoni v Tsimhoni (Oakland County Circuit Court, Michigan, 24 June 2015; Mich. Ct. App. Docket Nos. 329406 (2016) and 336868 (2018); In re Hon. Lisa O. Gorcyca, Mich. JTC Formal Complaint No. 98, Mich. Sup. Ct. order 2017)

Court: Oakland County Circuit Court (Family Division), Michigan
Decided: 2015-06-24
Panel: Hon. Lisa O. Gorcyca, sitting alone (trial level)

Why this case matters

Tsimhoni is the United States case that most uncomfortably captures everything that can go wrong when 'parental alienation' is deployed as a frame for coercive remedies against children themselves. On 24 June 2015 Oakland County Circuit Judge Lisa Gorcyca held three children aged nine, ten and thirteen in civil contempt for refusing an order to have lunch with their father, compared them on the record to the Charles Manson 'Family' cult, and committed them to Mandy's Place — a juvenile detention dormitory ordinarily reserved for abused and neglected children — where they remained for approximately two weeks until intense national press coverage forced an emergency release. The 2016 and 2018 Michigan Court of Appeals decisions addressed downstream custody orders; the Michigan Judicial Tenure Commission and Michigan Supreme Court found Judge Gorcyca's conduct at the 24 June hearing to be judicial misconduct and imposed public censure. A 2018 federal civil suit by the mother sought damages arising out of the detention. The case sits in the AntiAlienate corpus as the worked example of the proposition Re Y [2026] EWFC 38, BVerfG 1 BvR 1076/23 and Cassazione 9691/2022 make in their respective jurisdictions: even if alienation is genuinely present in a given case, the remedies must be lawful, proportionate, child-respecting and grounded in proper findings — contempt-and-detention against children is not.

Procedural history

Three parallel tracks. (1) Underlying custody case in Oakland County Circuit Court, Family Division: Dr Eibschitz-Tsimhoni and Mr Tsimhoni divorced in August 2011 following relocation from Israel to Michigan; the father subsequently moved back to Israel and remarried; the children remained with the mother in Bloomfield Hills. The matter was assigned to Judge Gorcyca and ran for approximately five years and more than 100 pleadings, with repeated motions invoking parental alienation as a framework for the children's refusal to spend time with their father. On 24 June 2015, after the three children refused an order to have lunch with their father at the Oakland County courthouse, Judge Gorcyca held the children in civil contempt and ordered them to Mandy's Place — a dormitory wing of the Children's Village juvenile facility ordinarily used for abused and neglected children. The children were detained there for approximately two weeks. After national and international press coverage (Detroit Free Press, Detroit News, Time, NYT, Forward, Haaretz, Slate, AP), the court convened an emergency hearing on or about 9 July 2015 and ordered the children released to a summer camp where both parents could visit. In August 2015 the children's principal residence was switched to the father in Israel under a reunification framework; the mother's contact was sharply curtailed. Dr Eibschitz-Tsimhoni filed motions for Judge Gorcyca to recuse herself; on refusal she escalated to Chief Judge Nanci Grant and Judge Gorcyca was ultimately removed from the case. (2) Appellate review: at least two unpublished opinions of the Michigan Court of Appeals — Docket No. 329406 (2016) and Docket No. 336868 (2018) — addressed downstream aspects of the custody orders; both are unpublished and non-precedential. (3) Judicial-conduct proceedings: the Michigan Judicial Tenure Commission filed Formal Complaint No. 98 against Judge Gorcyca arising out of her conduct at the 24 June 2015 hearing. The Michigan Supreme Court issued public censure in 2017 (lifting a brief suspension that had earlier been imposed by the JTC), finding that Judge Gorcyca had directed 'demeaning and disparaging remarks' at the children and had made false representations in writing to the Commission about her own conduct.

Counsel

  • Lisa Stern (attorney of record at the time of the children's release) — Michigan family-law bar for respondent mother (Dr Maya Eibschitz-Tsimhoni)
  • William Lansat (court-appointed guardian ad litem (GAL) for the three children) — Oakland County family-law bar for the three minor children

Experts

  • Not publicly named on the face of the released 24 June 2015 transcript — Reunification / parental-alienation framework was applied by the court without on-the-record reliance on a named court-appointed expert at the 24 June 2015 contempt hearing; downstream custody orders (Aug 2015 transfer of residence to the father in Israel) proceeded under a 'parental alienation' reunification framework whose specific expert authorship is not publicly confirmed (instructed by Oakland County Circuit Court (Family Division))

Holding

On the trial-court record of 24 June 2015, Judge Gorcyca purported to act under Michigan's civil-contempt power for the children's refusal to obey her parenting-time order; she characterised the children's behaviour as the product of brainwashing by their mother and described the situation as parental alienation on a scale she had not previously encountered in her caseload. The Michigan Supreme Court, on the JTC Formal Complaint No. 98, did NOT hold that no alienation existed; it held that Judge Gorcyca's HANDLING of the alleged alienation — the contempt sanction against children, the demeaning Manson-cult and IQ remarks, and false representations made in writing to the Commission about her own conduct — was judicial misconduct warranting public censure. The 2016 and 2018 unpublished Michigan Court of Appeals opinions addressed downstream custody-order appeals without disturbing the basic reunification-reversal framework. The doctrinal ratio for AntiAlienate purposes: even where a trial court finds parental alienation, juvenile-detention contempt against the children themselves is sanctionable judicial conduct, and the remedies of forced reunification must be lawful, child-respecting and grounded in proper findings — not coercion through the contempt power directed at minors.

Verbatim

24 June 2015 contempt hearing transcript (Oakland County Circuit Court, Family Division), reproduced in contemporaneous press (en):

Your children — you need to do a research program on Charlie Manson and the cult that he has. Your behavior in the hall with me months ago, your behavior in this courtroom, your behavior back there is unlike any I've seen in 46,000 cases.

https://jezebel.com/judge-jails-kids-compares-them-to-manson-cult-for-refu-1716809001

24 June 2015 contempt hearing transcript, address to L. Tsimhoni (eldest child), reproduced in Forward / Paul Berger (en):

You're supposed to have a high IQ, which I'm doubting right now because of the way you act, you're very defiant, you have no manners.

https://forward.com/news/311751/tshimoni-israeli-detroit-divorce-custody/

Michigan Supreme Court order on JTC Formal Complaint No. 98 (2017), public-censure operative wording as reported in Detroit News (en):

demeaning and disparaging remarks

Translation: Operative characterisation used by the Michigan Supreme Court to describe the substance of Judge Gorcyca's on-the-record conduct toward the three children at the 24 June 2015 hearing; ground of public censure together with the finding that she had made false representations in writing to the Judicial Tenure Commission about her own conduct.

https://www.detroitnews.com/story/news/local/oakland-county/2016/07/01/judge-lisa-gorcyca-guilty-hearing/86609062/

Outcome

At trial level: on 24 June 2015 the three children were held in civil contempt and committed to Mandy's Place / Children's Village juvenile facility; emergency release ordered on or about 9 July 2015 (children released to a summer camp where both parents could visit); in August 2015 the children's principal residence was switched to the father in Israel under a parental-alienation reunification framework, with the mother's contact sharply curtailed (later partially restored to approximately 68% of pre-order time per 2016 mother-side public statements). Judge Gorcyca subsequently removed from the case after Chief Judge Nanci Grant heard the recusal escalation. At appellate level: Mich. Ct. App. Docket No. 329406 (2016) and Docket No. 336868 (2018), both unpublished and non-precedential, addressed downstream custody orders without disturbing the underlying reversal framework. At judicial-conduct level: Michigan Supreme Court 2017 order of public censure on JTC Formal Complaint No. 98 (lifting an earlier brief suspension); findings of demeaning-and-disparaging remarks to the children and of false representations in writing to the Commission. 2018 federal civil suit by Dr Eibschitz-Tsimhoni seeking damages arising out of the detention; outcome of the federal civil suit not publicly fully confirmed in the open-press record assembled for this case study.

Comparative jurisprudence

  • L. (A.G.) v. D. (K.B.) (2009), 93 O.R. (3d) 409 (Ont. S.C.J.) — 2009 CanLII 943 (ON SC) (CA) — lag-v-dkb-2009-ontario — Paradigm modern Anglo / common-law parental-alienation custody-reversal authority. Where L.(A.G.) v D.(K.B.) institutionalised the reversal-plus-out-of-country-reunification template in Canada via measured trial-level reasoning, Tsimhoni shows what the same reunification-reversal logic looks like when the trial court is willing to coerce the children themselves through the contempt power. Tsimhoni is the cautionary-tale shadow of the L.(A.G.) v D.(K.B.) template.
  • Re Y (Experts and Alienating Behaviour: The Modern Approach) [2026] EWFC 38 (UK-EWS) — re-y-2026-ewfc-38 — English Family Court (McFarlane P) set aside first-instance findings of 'alienating behaviour' built on the report of an unregulated PA 'specialist'. The Re Y principle — even where alienation is alleged, the remedies must rest on properly regulated expert evidence, lawful process and child-respecting reasoning — is the doctrinal correction that the Tsimhoni 24 June 2015 hearing most starkly violates. Tsimhoni is the worked US-state-court example of what Re Y refuses to authorise in England and Wales.
  • BVerfG 17.11.2023 — 1 BvR 1076/23 (DE) — bverfg-1-bvr-1076-23-germany-2023 — German Federal Constitutional Court constitutional critique of PAS-based Sachverständigengutachten on Art. 6 Abs. 2 GG / Kindeswohl grounds. Reinforces the Tsimhoni teaching that even properly diagnosed alienation does not authorise coercive remedies that override the constitutional protection of the child's own personality and dignity — the precise interests Judge Gorcyca's Manson-cult and IQ remarks injured on the open court record.

Subsequent reception

  • Detroit News (2016) — Oralandar Brand-Williams, 'Judge Gorcyca guilty of misconduct in custody case,' Detroit News, 1 July 2016 — https://www.detroitnews.com/story/news/local/oakland-county/2016/07/01/judge-lisa-gorcyca-guilty-hearing/86609062/
  • Detroit News reporting of the Michigan Judicial Tenure Commission finding of judicial misconduct against Judge Gorcyca; primary newspaper-of-record source for the JTC track.
  • Michigan Court of Appeals (unpublished) (2016) — Eibschitz-Tsimhoni v Tsimhoni, Mich. Ct. App. unpublished opinion, Docket No. 329406 (2016) — https://law.justia.com/cases/michigan/court-of-appeals-unpublished/2016/329406.html
  • 2016 unpublished Michigan Court of Appeals opinion addressing aspects of the post-Gorcyca custody orders. Non-precedential.
  • Michigan Court of Appeals (unpublished) (2018) — Eibschitz-Tsimhoni v Tsimhoni, Mich. Ct. App. unpublished opinion, Docket No. 336868 (2018) — https://law.justia.com/cases/michigan/court-of-appeals-unpublished/2018/336868.html
  • 2018 unpublished Michigan Court of Appeals opinion addressing further downstream custody-order issues. Non-precedential. Together with Docket 329406 forms the appellate trail through which residence and contact arrangements continued to be litigated for years after Judge Gorcyca's removal.
  • Michigan Supreme Court / Michigan Judicial Tenure Commission (2017) — In re Hon. Lisa O. Gorcyca, Mich. JTC Formal Complaint No. 98; Michigan Supreme Court order of public censure, 2017 — https://www.usnews.com/news/articles/2015-12-15/judge-who-jailed-kids-for-refusing-lunch-with-dad-may-face-removal
  • Michigan Supreme Court 2017 order of public censure on the JTC Formal Complaint No. 98 — finding demeaning and disparaging remarks to the children and false representations in writing to the Commission; lifted an earlier brief suspension imposed by the JTC. The disciplinary ruling is the hard data point that the methods of forced reunification deployed at the 24 June 2015 hearing — contempt against children, juvenile detention, public ridicule from the bench — are not merely controversial, they are sanctionable.
  • Federal civil suit (2018) — Eibschitz-Tsimhoni v Gorcyca et al. (E.D. Mich., 2018) — federal civil action by Dr Maya Eibschitz-Tsimhoni seeking damages arising out of the June–August 2015 juvenile detention of the three children — https://www.courthousenews.com/judge-releases-kids-she-jailed-in-divorce-case/
  • 2018 federal civil suit by the mother seeking damages arising out of the children's June–August 2015 detention. Filing widely reported in the Detroit press; outcome of the federal civil suit is not publicly fully confirmed in the open-press record assembled for this case study (typical disposition issues include judicial immunity defences for the named judge and procedural-bar issues for derivative claims against county institutions).
  • Time Magazine (2015) — Time — coverage of the Tsimhoni detention and parental-alienation framing (July 2015) — https://time.com/
  • Time-magazine-level national US press coverage of the Tsimhoni detention; principal vehicle by which the case entered the mainstream parental-alienation discourse outside Michigan.
  • New York Times (2015) — New York Times — coverage of the Tsimhoni case and Michigan Judicial Tenure Commission proceedings (2015–2017) — https://www.nytimes.com/
  • NYT-level US newspaper-of-record coverage spanning the initial detention, the press-coverage-driven emergency release, and the subsequent JTC and Michigan Supreme Court disciplinary proceedings.
  • Slate (2015) — Slate — commentary on the Tsimhoni hearing and the use of contempt power against children — https://slate.com/
  • Slate-style national legal-commentary coverage of the 24 June 2015 hearing; representative of the US public-affairs commentary line that read the hearing as a textbook abuse of the civil-contempt power directed at minors.
  • Associated Press (2015) — AP — wire coverage of the Tsimhoni detention, release and subsequent judicial-conduct proceedings (2015–2017) — https://apnews.com/
  • AP wire reporting carried by US local and national outlets across the lifecycle of the case; the principal vehicle through which the Tsimhoni story reached non-Detroit US local press.
  • Forward (Paul Berger) (2015) — Paul Berger, '3 Israeli-American Children Sent to Juvenile Detention,' The Forward, July 2015 — https://forward.com/news/311751/tshimoni-israeli-detroit-divorce-custody/
  • Forward coverage framing the case as the collision of Israeli-American transnational families with US state-court custody machinery; principal source for the verbatim Gorcyca 'high IQ' address to the eldest child.
  • Haaretz (Allison Kaplan Sommer) (2015) — Allison Kaplan Sommer, 'Jailed Michigan Kids Are Victims of Israeli-American Divorce Nightmare,' Haaretz, 10 July 2015 — https://www.haaretz.com/.premium-jailed-michigan-kids-are-victims-of-israeli-american-divorce-nightmare-1.5376082
  • Israeli newspaper-of-record framing of the case; central to the international press dimension and to the eventual emergency release.
  • Innocence Project (2015) — Innocence Project — 'Tsimhoni Children Released from Juvenile Detention' — https://innocenceproject.org/news/tsimhoni-children-released-from-juvenile-detention/
  • NGO commentary arguing the case demonstrated how easily children's voices are overridden in the family-court system; included in the academic / civil-society reception layer.
  • Courthouse News Service (2015) — Courthouse News — 'Judge Releases Kids She Jailed in Divorce Case' — https://www.courthousenews.com/judge-releases-kids-she-jailed-in-divorce-case/
  • Courthouse News reporting of the emergency release order on or about 9 July 2015; principal procedural-press source for the release-order leg of the procedural history.
  • Michigan Bar Journal / Michigan Bar professional-responsibility commentary (2017) — Michigan Bar coverage of In re Hon. Lisa O. Gorcyca and the JTC Formal Complaint No. 98 (2016–2017) — https://www.michbar.org/
  • Michigan-bar professional-responsibility commentary on the JTC proceedings and the Michigan Supreme Court public censure; representative of the in-state bar reception of the disciplinary ruling.
  • Georgialee Lang KC (Canadian family-law commentator) (2015) — Georgialee Lang, 'Part 2: Alienated Kids Released From Jail' (LinkedIn longform essay) — https://www.linkedin.com/pulse/part-2-alienated-kids-released-from-jail-georgialee-lang-ba-jd-fciarb
  • Canadian PA-recognition-aligned commentator's multi-part series on the case; representative of the trans-Anglo PA-discourse reception.

See also

  • case-study:lag-v-dkb-2009-ontario
  • case-study:re-y-2026-ewfc-38
  • case-study:bverfg-1-bvr-1076-23-germany-2023
  • practitioner:us.lorandos-demosthenes
  • practitioner:us.warshak-richard
  • jurisdiction:united-states

Sources

  1. Eibschitz-Tsimhoni v Tsimhoni, Mich. Ct. App. unpublished opinion, Docket No. 336868 (2018) — https://law.justia.com/cases/michigan/court-of-appeals-unpublished/2018/336868.html (Michigan Court of Appeals / Justia) [en] — accessed 2026-05-30
  2. Eibschitz-Tsimhoni v Tsimhoni, Mich. Ct. App. unpublished opinion, Docket No. 329406 (2016) — https://law.justia.com/cases/michigan/court-of-appeals-unpublished/2016/329406.html (Michigan Court of Appeals / Justia) [en] — accessed 2026-05-30
  3. Courthouse News — 'Judge Releases Kids She Jailed in Divorce Case' — https://www.courthousenews.com/judge-releases-kids-she-jailed-in-divorce-case/ (Courthouse News Service) [en] — accessed 2026-05-30
  4. Innocence Project — 'Tsimhoni Children Released from Juvenile Detention' — https://innocenceproject.org/news/tsimhoni-children-released-from-juvenile-detention/ (Innocence Project) [en] — accessed 2026-05-30
  5. Detroit News — Oralandar Brand-Williams, 'Judge Gorcyca guilty of misconduct in custody case' (1 July 2016) — https://www.detroitnews.com/story/news/local/oakland-county/2016/07/01/judge-lisa-gorcyca-guilty-hearing/86609062/ (Detroit News) [en] — accessed 2026-05-30
  6. CBS Detroit — 'Judge Violated Rules Of Conduct In Child Custody Case, Commission Says' — https://www.cbsnews.com/detroit/news/judge-violated-rules-of-conduct-in-child-custody-case-commission-says/ (CBS Detroit / WWJ) [en] — accessed 2026-05-30
  7. US News — 'Judge Who Jailed Kids for Refusing Lunch With Dad May Face Removal' (15 December 2015) — https://www.usnews.com/news/articles/2015-12-15/judge-who-jailed-kids-for-refusing-lunch-with-dad-may-face-removal (US News & World Report (AP wire)) [en] — accessed 2026-05-30
  8. WZZM-13 — 'Michigan high court lifts suspension on judge who jailed kids in custody fight' — https://www.wzzm13.com/article/news/local/michigan/michigan-high-court-lifts-suspension-on-judge-who-jailed-kids-in-custody-fight/69-460268589 (WZZM-13 (ABC affiliate, West Michigan)) [en] — accessed 2026-05-30
  9. Forward / Paul Berger — '3 Israeli-American Children Sent to Juvenile Detention' — https://forward.com/news/311751/tshimoni-israeli-detroit-divorce-custody/ (The Forward) [en] — accessed 2026-05-30
  10. Haaretz / Allison Kaplan Sommer — 'Jailed Michigan Kids Are Victims of Israeli-American Divorce Nightmare' — https://www.haaretz.com/.premium-jailed-michigan-kids-are-victims-of-israeli-american-divorce-nightmare-1.5376082 (Haaretz) [en] — accessed 2026-05-30
  11. Patch / Beth Dalbey — 'Bloomfield Hills Children's Mother Persists in Fight to Remove Judge' — https://patch.com/michigan/bloomfield-mi/bloomfield-hills-childrens-mother-persists-fight-remove-judge (Patch (Bloomfield-MI local newsroom)) [en] — accessed 2026-05-30
  12. Patch / Beth Dalbey — 'Judge in Bitter Custody Dispute Could Recuse Herself' — https://patch.com/michigan/bloomfield-mi/judge-bitter-custody-dispute-could-recuse-herself (Patch (Bloomfield-MI local newsroom)) [en] — accessed 2026-05-30
  13. Jezebel — transcript excerpts of the 'Manson cult' remark by Judge Gorcyca — https://jezebel.com/judge-jails-kids-compares-them-to-manson-cult-for-refu-1716809001 (Jezebel) [en] — accessed 2026-05-30
  14. Detroit Free Press — coverage of the Tsimhoni case (24 June 2015 hearing, July 2015 emergency release, and subsequent JTC proceedings) — https://www.freep.com/ (Detroit Free Press) [en] — accessed 2026-05-30
  15. Time Magazine — coverage of the Tsimhoni detention and the parental-alienation framing (July 2015) — https://time.com/ (Time Magazine) [en] — accessed 2026-05-30
  16. New York Times — coverage of the Tsimhoni case and Michigan Judicial Tenure Commission proceedings (2015–2017) — https://www.nytimes.com/ (New York Times) [en] — accessed 2026-05-30
  17. Associated Press — wire coverage of the Tsimhoni detention, release and subsequent judicial-conduct proceedings (2015–2017) — https://apnews.com/ (Associated Press) [en] — accessed 2026-05-30
  18. Slate — commentary on the Tsimhoni hearing and the use of the contempt power against children — https://slate.com/ (Slate) [en] — accessed 2026-05-30
  19. Michigan Bar Journal / Michigan Bar professional-responsibility commentary on In re Hon. Lisa O. Gorcyca and JTC Formal Complaint No. 98 — https://www.michbar.org/ (State Bar of Michigan) [en] — accessed 2026-05-30
  20. Georgialee Lang KC — 'Part 2: Alienated Kids Released From Jail' (LinkedIn longform essay) — https://www.linkedin.com/pulse/part-2-alienated-kids-released-from-jail-georgialee-lang-ba-jd-fciarb (Georgialee Lang KC (Canadian family-law commentator)) [en] — accessed 2026-05-30
  21. Demosthenes Lorandos, William Bernet & S. Richard Sauber (eds.), 'Parental Alienation: Science and Law' (Charles C. Thomas, 2020) — recognition-aligned US practitioner commentary on Tsimhoni as a case study in alienation litigation — https://www.ccthomas.com/details.cfm?P_ISBN13=9780398093259 (Charles C. Thomas) [en] — accessed 2026-05-30
  22. Richard A. Warshak, 'Divorce Poison' and related US-side recognition commentary on the Tsimhoni framing of parental alienation in US state-court practice — https://warshak.com/ (Richard A. Warshak / warshak.com) [en] — accessed 2026-05-30
  23. West Michigan Divorce blog — contextual coverage of the mother's contact restoration in the post-Gorcyca period — https://westmichigandivorce.com/prevented-from-seeing-their-mother-in-grisly-custody-battle/ (West Michigan Divorce (Michigan family-law practice resource)) [en] — accessed 2026-05-30
  24. Divorce Lawyers For Men — pro-father commentary 'Tsimhoni v Tsimhoni: parental alienation and ultimate consequences' — https://www.divorcelawyersformen.com/blog/tsimhoni-v-tsimhoni-parental-alienation-and-ultimate-consequences/ (Divorce Lawyers For Men (US men's-side family-law practice)) [en] — accessed 2026-05-30

Editorial notes

  • Public-figures-vs-anonymisation tension: ordinarily the AntiAlienate corpus anonymises children per the deciding court's convention. Tsimhoni is an exceptional case in that (i) the parents Maya Eibschitz-Tsimhoni and Omer Tsimhoni are publicly named in court-of-record transcripts, Michigan Court of Appeals captioning (Eibschitz-Tsimhoni v Tsimhoni), Michigan Judicial Tenure Commission filings and pervasive US, Israeli and UK press coverage including Detroit Free Press, Detroit News, Time, NYT, AP, Forward, Haaretz, Slate, Patch and CBS Detroit; (ii) the eldest child L. Tsimhoni (Liam Tsimhoni) was publicly identified in 2018 sentencing reportage and in contemporaneous press; (iii) the children's names appeared in widespread press coverage during their minority. This case-study preserves court-anonym style 'L. / R. / N. Tsimhoni' in the children-fields while flagging the contemporaneous press names in the notes field, to allow downstream rendering to choose the appropriate level of identification per publication context. The default editorial preference for AntiAlienate published derivatives is to use the initialed form for the children in headlines and body text and to confine the contemporaneous press names to a single footnote of public-record acknowledgment.
  • Verbatim Gorcyca quotations at the 24 June 2015 hearing are reproduced from contemporaneous press transcript excerpts (Jezebel, Forward) and not from a primary court-released transcript link in this case-study; the Detroit Free Press, Detroit News and AP wire coverage all reproduce the same transcript fragments and confirm the wording used here. The Michigan Supreme Court / JTC operative characterisation 'demeaning and disparaging remarks' is reproduced as quoted in the Detroit News and US News & World Report (AP) coverage of the 2017 censure.
  • 2016 Michigan Court of Appeals (Docket 329406) and 2018 Michigan Court of Appeals (Docket 336868) opinions are unpublished and non-precedential under Michigan appellate practice; they are included for the appellate-trail completeness rather than for any doctrinal holding.
  • 2018 federal civil suit: filing reported in Detroit-area press; final disposition of the federal civil action is not publicly fully confirmed in the open-press record assembled for this case study, and the case-study marks this gap in the procedural-history and outcome fields rather than assert a disposition.
  • JTC discipline: verified through Detroit News (1 July 2016, Brand-Williams), CBS Detroit, US News & World Report (AP wire, 15 December 2015) and WZZM-13 (Michigan high court lifts suspension). The Michigan Supreme Court 2017 public-censure order on JTC Formal Complaint No. 98 is the operative disciplinary ruling.
  • Comparative cross-links: lag-v-dkb-2009-ontario (CA — Anglo PA recognition-template parent case), re-y-2026-ewfc-38 (UK-EWS — modern English correction of the unregulated-expert / coercive-remedy pattern) and bverfg-1-bvr-1076-23-germany-2023 (DE — constitutional critique of PAS-based reasoning) form the AntiAlienate triangulation that situates Tsimhoni as the worked US-state-court example of the very remedy-pattern those three jurisdictions are now reining in.
  • Practitioner cross-links: us.lorandos-demosthenes and us.warshak-richard are the principal US PA-recognition-aligned practitioner commentators; the case-study includes them as recognition-side reference points without endorsing any particular doctrinal characterisation of Tsimhoni as either a 'PA success story' or a 'PA litigation failure' — that contested framing is itself part of the Tsimhoni reception.
  • Author: Alan Markson; license: CC-BY-4.0; schema_version 1.0.

Author: Alan Markson.

Licensed CC BY 4.0 — AntiAlienate Knowledge. Source of truth is the sibling .json; this .md is rendered. Do not hand-edit.